Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Indiana

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and other crimes and sentencing him to life without parole, holding that each of Defendant's contentions on appeal were without merit. Specifically, the Court held (1) sufficient evidence supported Defendant's conviction for auto theft, and the Court needn't address Defendant's felony-murder challenge because the trial court merged those verdicts with his murder convictions; (2) any error in the trial court's admonishments to the jurors each time they were separated wasn't fundamental; (3) the trial court did not violate Defendant's Confrontation Clause rights by admitting post-crime text messages of Defendant's co-conspirator because the messages weren't testimonial; (4) any error in the decision of the trial court to read a withdrawn accomplice liability instruction was harmless; and (5) the trial court did not manifestly abuse its discretion when it sentenced Defendant to life without parole. View "Cardosi v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of Class A misdemeanor domestic battery, holding that Defendant did not validly waive his right to a jury trial. In the underlying proceedings Defendant signed two advisement of rights forms. By the time he signed the second form the deadline to request a jury trial had passed. Neither form advised Defendant of the timeline to file a demand for a jury trial and that his failure to file a demand within that period would result in the waiver of his right. Further, the first advisement of rights did not inform Defendant that his demand for a jury trial had to be in writing. The Supreme Court held that Defendant did not validly waive his right to a jury trial. Because the evidence was sufficient to support the conviction, the Court noted that the State was free to retry Defendant. View "Dadouch v. State" on Justia Law

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The Supreme Court affirmed the judgment of the superior court ruling that Indiana's Civil Forfeiture Statute was constitutional, holding that the General Assembly may decide how and when forfeiture proceeds accrue to the "Common School Fund," which consists of, among other sources of revenue, "all forfeitures which may accrue." Indiana's Civil Forfeiture Statute, Ind. Code 34-24-1-4(d), directs the transfer of proceeds from seized property "to the treasurer of state for deposit in the common school fund." At issue in this case is whether the portion of the statute permitting the allocation of forfeiture revenue to reimburse law enforcement costs before these proceeds accrue to the Fund is constitutional under article 8, section 2 of the Indiana Constitution. The trial court concluded that the statute is constitutional. The Supreme Court affirmed, holding that article 8, section 2 permits the legislature to determine how and when forfeiture proceeds accrue to the Common School Fund. View "Horner v. Curry" on Justia Law

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The Supreme Court affirmed the decision of the trial court ordering state police officers to turn over to federal authorities a shipped box containing U.S. currency wrapped in multiple layers of sealed packaging that bore the odor of narcotics, holding that the totality of the circumstances established the requisite probable cause to believe the money was proceeds of drug trafficking. The shipped box in this case displayed hallmarks of parcels containing drugs and drug money. The officer sought and was granted a warrant authorizing a search of the package and seizure of proceeds of drug trafficking. Officers proceeded to open the box, and a canine alerted that the money contained therein, and not just the packaging surrounding it, contained the odor of narcotics. The officers then seized the cash and obtained a court order to turn it over to federal authorities. Appellant, the individual who shipped the parcel, argued on appeal that the seizure exceeded the scope of the warrant. The Supreme Court affirmed, holding (1) all the circumstances supplied a basis for probable cause to believe the cash was proceeds of drug trafficking; and (2) therefore, the seizure was lawful, and the trial court properly made its order transferring the property to the federal government. View "Hodges v. State" on Justia Law

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The Supreme Court granted transfer in this case to eliminate a residual double jeopardy violation not addressed by the court of appeals, holding that one of Defendant's remaining convictions must be reduced to a lesser included offense to eliminate the violation. Defendant was convicted of possession of cocaine, enhanced to a level four felony; possession of a narcotic drug, enhanced to a level five felony; and unlawful possession of a firearm by a serious violent felon and adjudicated a habitual offender. On appeal, Defendant argued that his conviction for firearm possession and the enhancements applied to the drug-related counts violated double jeopardy principles because they were based on the same evidence - his possession of a single firearm. The court of appeals affirmed Defendant's drug-related convictions but reversed and vacated the conviction and sentence for the firearm possession conviction. The Supreme Court held that because Defendant's two drug-related convictions were enhanced based on the same evidence of his possession of a single firearm, Defendant's conviction on possession of a narcotic drug must be remanded for entry of judgment as a level six felony. View "Springfield v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court granting Defendant's motion to suppress statements he made during an interrogation as inadmissible in his criminal trial, holding that there was substantial, probative evidence that Defendant was in custody at the time of the interrogation. Two police officers interrogated Defendant in a secured area at a police station without providing him with required Miranda warnings. In granting Defendant's motion to suppress, the trial court determined that the environment in which Defendant was interrogated was a "police setting." The Supreme Court affirmed, holding that the totality of the circumstances supported the trial court's conclusion that the interrogation was custodial. View "State v. Ruiz" on Justia Law

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The Supreme Court held that the Fee Exemption, a provision in Ind. Code 36-1-20-5 that allows the cities of Bloomington and West Lafayette to charge local landlords any amount to register rental properties, is unconstitutional special legislation that must be struck down but that the remainder of section 36-1-20-5 remains in force. While the Fee Exemption singles out the cities of Bloomington and West Lafayette for preferential treatment, all other Indiana localities are restricted to charging only $5 under another provision - the Fee Restriction - in section 36-1-20-5. The City of Hammond challenged the Fee Exemption as unconstitutional under Ind. Const. art. IV, 23. The Supreme Court agreed with the City and held that the Fee Exemption is unconstitutional but that the remainder of the statute, including the Fee Restriction, remained in effect and now operates statewide. View "City of Hammond v. Herman & Kittle Properties, Inc." on Justia Law

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The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt. Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt. View "Zanders v. State" on Justia Law

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The Supreme Court reversed the judgment of the lower courts denying Appellant’s petition for post-conviction relief on the basis that his attorney provided deficient performance that prejudiced him, holding that counsel rendered ineffective assistance to Appellant by failing to properly advise him about the immigration consequences of a misdemeanor guilty plea. Appellant pleaded guilty to stealing less than twenty dollars of merchandise from Walmart without realizing that his guilty plea made him a deportable felon under federal immigration law. Appellant sought post-conviction relief, alleging ineffective assistance of counsel. The lower courts denied relief. The Supreme Court reversed, holding (1) Appellant’s attorney rendered constitutionally deficient performance as a matter of law by independently marking “N/A” next to the citizenship advisement on the standard advisement of rights from before inquiring into Appellant’s citizenship status; and (2) counsel’s deficient performance prejudiced Appellant. View "Bobadilla v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained after Defendant was stopped for speeding, holding that there was reasonable suspicion for a traffic stop under the circumstances. At issue was whether there was reasonable suspicion for the traffic stop where the police officer’s calibrated radar indicated that an oncoming vehicle was speeding and the officer verified the radar speed exceeded the posted speed limit but failed to document the excessive speed. The trial court denied Defendant’s motion to suppress on the basis that the officer’s stop of Defendant was based upon his observation that a traffic infraction was being committed. The Supreme Court affirmed, holding that the traffic stop passed muster under both the United States and Indiana Constitutions. View "Marshall v. State" on Justia Law