Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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The Supreme Court reversed in part and affirmed in part the order of the trial court finding that HEA-1123 is constitutional, holding that Governor Eric J. Holcomb was not procedurally barred from seeking declaratory relief on the constitutionality of House Enrolled Act 1123 (HEA-1123) and that the law is unconstitutional.HEA-1123, which was passed during the COVID-19 pandemic, authorizes the General Assembly to commence an "emergency session" under certain conditions through a simple resolution. The Governor vetoed the bill, finding it unconstitutional. The General Assembly overrode the Governor's veto, and the law went into effect. The Governor filed suit. The trial court found the HEA-1123 was constitutional. The Supreme Court reversed, holding (1) HEA-1123 violates Ind. Const. art. III, 1; and (2) by authorizing the Legislative Council to set an emergency session at a time when the General Assembly was not in session, HEA-1123 infringed on constitutional authority vested only in the Governor. View "Holcomb v. Bray" on Justia Law

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The Supreme Court reversed Defendant's conviction of one count of felony child molestation, holding that the trial court denied Defendant's requests for a continuance.An impermissible local rule and an improperly issued protective order prevented Defendant's defense attorney from obtaining a copy of the alleged victim's interview. Further, the trial court denied Defendant's requests for a continuance when the state disclosed extensive new evidence the day before trial in order to investigate the new allegations and reconstruct trial strategy. The Supreme Court reversed, holding that the trial court (1) erred in prohibiting Defendant from obtaining a copy of the interview before trial, but reversal was not required on this basis; and (2) abused its discretion by denying Defendant's continuance request, and the error was prejudicial. View "Ramirez v. State" on Justia Law

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The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant did not receive ineffective assistance of counsel at sentencing, holding that Defendant did not receive ineffective assistance of counsel.Defendant was convicted of murdering his brother when Defendant was seventeen years old. Defendant sought post-conviction relief alleging that he received ineffective assistance of counsel at sentencing. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that counsel's performance fell objectively below professional norms or that he was prejudiced by any of counsel's alleged errors. View "Conley v. State" on Justia Law

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The Supreme Court reversed the judgment of the trial court granting Defendant's motion to dismiss the charges brought against him and finding that Ind. Code 35-45-4-8 violated the state and federal constitutions, holding that the State alleged an offense and that the statute is constitutional.Defendant captured cell phone video of his girlfriend performing oral sex on him and then sent it to another person. Defendant was charged under section 35-45-4-8, which criminalizes the non-consensual distribution of an "intimate image." Defendant filed a motion to dismiss, arguing that the statute was unconstitutional on free speech grounds. The trial court granted the motion, finding the statute unconstitutional. The Supreme Court reversed, holding (1) the State properly charged Defendant with violating section 35-45-4-8; and (2) the statute does not violate either the free interchange clause of the Indiana Constitution or the First Amendment to the United States Constitution. View "State v. Katz" on Justia Law

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The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant's counsel was not ineffective during his criminal proceedings, holding that counsel provided constitutionally effective assistance.Defendant, who was fifteen years old at the time, was charged as an adult and convicted of murder as an accomplice with a gang enhancement after his friend shot and killed a toddler while firing on a rival during a gang dispute. Defendant sought post-conviction relief, alleging that his trial counsel provided ineffective assistance. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to demonstrate that his counsel was ineffective. View "Bradbury 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 on the grounds that the affidavit supporting the search warrant failed to specify the deputies' "training and experience" in detecting the odor of raw marijuana, holding that the trial court did not err.Defendant was charged with dealing in marijuana and possession of marijuana. Defendant filed a motion to suppress, arguing that the search violated his constitutional rights because the affidavit failed to specify the deputies' training and experience in detecting a specific smell. The trial court denied the motion to suppress. The Supreme Court affirmed, holding, as an issue of first impression, that trained and experienced law enforcement officers who affirm that they detect the odor of raw marijuana based on their training and experience may establish probable cause without providing further details on their qualifications to recognize this specific odor. View "Bunnell v. State" on Justia Law

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The Supreme Court affirmed the judgment of the post-conviction court denying Appellant's petition for post-conviction relief raising challenges to the effectiveness or his trial and appellate counsel, holding that Appellant's claims failed, and he was not entitled to relief.Appellant was convicted of three counts of murder and three counts of criminal recklessness and was sentenced to death. Appellant later filed a petition for post-conviction relief, alleging several claims of ineffective assistance of trial counsel. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claims that his trial counsel were constitutionally ineffective at all phases of Appellant's trial; (2) appellate counsel were not ineffective for failing to raise fundamental-error challenges on direct appeal concerning certain instructions; and (3) Appellant was not entitled to relief on his freestanding challenges to the post-conviction court's rulings. View "Isom v. State" on Justia Law

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The Supreme Court reversed the order of the trial court suppressing statements made by Defendant during a police interview, holding that the circumstances did not amount to a custodial interrogation.At issue was whether Defendant's freedom of movement was curtailed to a level associated with formal arrest when he had a free-flowing exchange in a detective's personal office. In granting Defendant's motion to suppress the trial court concluded that the circumstances were akin to a custodial interrogation and that the statements were obtained in violation of the Fifth Amendment. The Supreme Court disagreed and reversed the suppression order, holding that the limited curtailment of Defendant's freedom of movement did not amount to a formal arrest. View "State v. Diego" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress the fruits of an inventory search of the company van he was driving, holding that the van's seizure and search were lawful.Defendant was driving his company van when we served off the road, demolished a utility box, then drove to his nearby home. The responding officer found Defendant as he was parking in his front driveway and took him to the hospital for a blood test. Later, other officers conducted an inventory search of the van, which revealed pills in a bag under the driver's seat, and then towed the van as evidence of leaving the scene of an accident. Defendant was charged with several offenses and moved to suppress the pills. The trial court denied the motion to suppress, and a jury convicted Defendant of most of the charges. The Supreme Court affirmed, holding that the search and seizure of Defendant's van fell under recognized exceptions to the warrant requirement of the Fourth Amendment, and therefore, the police officers lawfully discovered the pills. View "Combs v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court denying Defendant's request to represent himself during trial, holding that the trial court did not err in denying Defendant's request to self-represent.Defendant was charged with, among other things, murder and felony burglary. Defendant petitioned the trial court to represent himself, but the trial court denied the petition, concluding that Defendant equivocated in his desire to self-represent and that the request was based upon a misapprehended understanding of the law. The Supreme Court affirmed, holding (1) while Defendant's waiver of the right to counsel was knowing and voluntary, his waiver was neither unequivocal nor intelligent; and (2) therefore, the trial court properly denied Defendant's request to represent himself. View "Wright v. State" on Justia Law