Justia Constitutional Law Opinion Summaries

After a bench trial, Defendant was convicted of two counts of sexual misconduct with a minor as class B felonies. The trial court sentenced Defendant to maximum consecutive terms after finding "substantial aggravating circumstances" and no mitigating circumstances. The court of appeals revised the sentence to concurrent terms of twenty years, finding that Defendant's forty-year sentence was not proportionate in comparison to Walker v. State and Harris v. State. The Supreme Court granted transfer and affirmed the sentence imposed by the trial court, holding that the sentence in this case was not inappropriate under Ind. R. App. 7(B) and did not warrant appellate revision. View "Chambers v. State" on Justia Law

Defendant was charged with the murder of his mother. He was subsequently found guilty but mentally ill and ultimately sentenced to fifty-five years' incarceration. Defendant filed an amended petition for post-conviction relief, alleging that his trial counsel rendered ineffective assistance for, inter alia, failing to object to the trial court's tendered instruction on the penal consequences of verdicts for not responsible by reason of insanity and guilty but mentally ill. Defendant's petition was denied. The Supreme Court affirmed, holding that Defendant failed to satisfy the prejudice prong of Strickland v. Washington and therefore could not prevail on his ineffective assistance claim. View "Passwater v. State" on Justia Law

Defendant was stopped by a police officer due to his darkly-shaded tinted windows. The police officer smelled marijuana and subsequently searched Defendant's person, where he found cocaine. The State charged Defendant with felony possession of cocaine. Defendant moved to suppress the evidence, arguing that the officer lacked probable cause to stop him and search his person. The trial court denied the motion, concluding that, although the tint of the windows on Defendant's car was within the statutorily defined limits, the officer's good faith subjective belief of Defendant's violation of a traffic law was enough to justify the initial stop. The Supreme Court affirmed, holding (1) the officer had reasonable suspicion that the tint on Defendant's vehicle's windows was in violation of the window tint statute, and therefore, the initial stop was justified; (2) the officer had probable cause to search Defendant's person after smelling marijuana; and (3) because the search was legal, the trial court correctly denied Defendant's motion to suppress the evidence obtained from the search. View "Sanders v. State" on Justia Law

After Defendant was charged with murder, he filed a motion seeking bail. At the same time, Defendant filed a motion seeking a declaration that Ind. Code 35-33-8-2(b), which assigns to a defendant charged with murder the burden of showing he is entitled to bail, is unconstitutional. The trial court denied Defendant bail. The Supreme Court declared the statute unconstitutional but nevertheless affirmed, holding (1) when a defendant charged with murder seeks bail, the burden must be placed on the State to prove by a preponderance of the evidence that the defendant should be denied bail; but (2) under the circumstances presented in this case, the trial court did not err in denying Defendant bail. View "Fry v. State" on Justia Law

After certain members of the Indiana House of Representatives Democratic Caucus left the state to prevent the formation of a quorum in order to block a vote on impending legislation, House Republicans passed motions to fine the absent legislators. The fines were withheld from the legislators' pay. Plaintiffs brought suit seeking to recover the withheld pay. The trial court concluded that the determination of the fine was outside the court's jurisdiction because the determination of the fine was within the House's "exclusive constitutional authority" but that review of the collection of fines was within the court's jurisdiction. The court then ordered return of the withheld pay and issued an injunction preventing future withholding. The Supreme Court reversed, holding that when, as here, the Indiana Constitution expressly assigns certain functions to the legislative branch without any contrary constitutional limitation or qualification, disputes arising in the exercise of such legislative powers are nonjusticiable, and the doctrine of separation of powers precludes judicial consideration of the claims for relief. Remanded for dismissal of Plaintiffs' claims for lack of justiciability. View "Berry v. Crawford" on Justia Law

Defendant was charged with murder and assisting suicide. Defendant requested to speak to an attorney while in police custody, but the following afternoon, detectives re-read Defendant his Miranda rights, and Defendant confessed his role in his father's death without counsel present. Defendant filed a motion to suppress the incriminating statements he made to the detective in response to police inquiries. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court reversed the denial of Defendant's motion to suppress, holding that the totality of the circumstances involving the content, place, and timing of the communication by the police with Defendant, notwithstanding Defendant's prior invocation of his right to counsel, constituted impermissible questioning or its functional equivalent. Remanded. View "Hartman v. State" on Justia Law

Defendant pled guilty to two counts of child molesting as class A felonies. The sentencing range for a class A felony is from twenty to fifty years, and the advisory sentence is thirty years. The trial court imposed consecutive advisory sentences for an aggregate term of sixty years. The court of appeals revised the sentences by ordering them to run concurrently pursuant to Ind. App. R. 7(B), thus reducing the aggregate term from sixty to thirty years. The Supreme Court affirmed the sentence imposed by the trial court, holding that the original sentence was not inappropriate under Rule 7(B) and did not warrant appellate revision. View "Merida v. State" on Justia Law

Defendant was convicted of attempted child molesting, a class A felony. The sentencing range for a class A felony is twenty to fifty years incarceration, and the advisory sentence is thirty years. The trial court imposed a sentence of forty years with five years suspended. The court of appeals revised the sentence to twenty years, the minimum term. The Supreme Court (1) affirmed the sentence imposed by the trial court, holding that the sentence was not inappropriate under Ind. App. R. 7(B) and did not warrant appellate revision; and (2) summarily affirmed the court of appeals in all other respects. View "Lynch v. State" on Justia Law

In 2008, a jury awarded John Doe $150,000 in punitive damages as part of a judgment in Doe's lawsuit against a priest for childhood sexual abuse. The priest moved to reduce the punitive damages pursuant to the statutory cap. The trial court denied the motion, holding that the statutory cap and allocation statutes violated the State Constitution's separation of governmental powers provision and right to a jury trial in civil cases provision. The State subsequently intervened. In 2011, the trial court issued an order declaring that the statutory cap and allocation statutes violated the separation of powers and right to a jury trial. The State appealed. The Supreme Court reversed, holding that the statutes did not violate the Indiana Constitution. Remanded with instructions to grant the priest's motion to reduce the punitive damages to the statutory maximum. View "State v. Doe" on Justia Law

Vincennes Indiana Girls, Inc. (VIG) deeded Camp Wildwood to the predecessor of Girl Scouts of Southern Illinois, Inc. (GSSI) on the condition that the property be used for scouting purposes for forty-nine years. The deed provided that ownership of the campground would revert to VIG if the scouting-use condition was breached during that time. After forty-four years, GSSI stopped using the camp as a Girl Scout facility and decided to sell. VIG sued to quiet title to Camp Wildwood and enjoin GSSI from selling the camp until the forty-nine-year period had expired. The trial court granted summary judgment quieting title in VIG. At issue on appeal was whether the forty-nine-year land use limitation was enforceable despite a subsequently enacted statute, Ind. Code 32-17-10-2, which purported to limit reversionary clauses in land transactions to a maximum of thirty years. The Supreme Court affirmed, holding that section 32-17-10-2 was unconstitutional as applied retroactively to the land-use restriction in VIG's deed to GSSI. View "Girl Scouts of S. Ill. v. Vincennes Ind. Girls, Inc." on Justia Law