Justia Constitutional Law Opinion Summaries
Articles Posted in Supreme Court of Indiana
Garcia v. State
Defendant was lawfully placed under arrest for driving without a valid driver’s license. Before the police officer placed Defendant in his police cruiser, he conducted a pat-down search of Defendant’s clothing to check for weapons. The officer discovered a pill container in Defendant’s pocket, opened the container, and found a single narcotic pill for which Defendant did not have a valid prescription. Defendant was charged with driving without a license and possession of a controlled substance. Defendant moved to suppress the evidence of the pill container’s contents, arguing that the officer’s opening of the pill contained was an unreasonable search. The trial court denied Defendant’s motion to suppress. The Supreme Court affirmed, holding that the opening of the pill container was within the scope of a search incident to a lawful arrest and reasonable under the Indiana Constitution. View "Garcia v. State" on Justia Law
Thornton v. State
Plaintiff brought several claims against multiple defendants arising out of his incarceration for a probation violation that occurred after his term of probation had expired. The trial court dismissed Plaintiff’s claims against all defendants. The court of appeals affirmed. Plaintiff sought transfer, contending that his claim against four individual probation officers under 42 U.S.C. 1983 was incorrectly dismissed for failure to state a claim. The Supreme Court granted transfer and reversed dismissal of Plaintiff’s section 1983 claim against the individually-named probation officers, holding that Plaintiff’s complaint stated a claim for relief under section 1983 against these defendants. View "Thornton v. State" on Justia Law
Comm’r of Ind. Bureau of Motor Vehicles v. Vawter
Plaintiffs, as a certified class, challenged the constitutionality of the program utilized by the Indiana Bureau of Motor Vehicles (BMV) in the processing of applications for personalized license plates (PLPs), arguing that the decision making process used in denying or revoking PLPs violates the First Amendment and the Due Process Clause. The trial court granted summary judgment in favor of the class, concluding that the statute that authorizes the BMV to refuse to issue PLPs and its related policies are vague, overbroad, and lacking in content-neutrality and that the Bureau violates due process safeguards by providing insufficient reasons for a denial or revocation of a PLP. The Supreme Court reversed, holding (1) PLPS are government speech; and (2) therefore, the statute and policies at issue in this case are constitutional. View "Comm’r of Ind. Bureau of Motor Vehicles v. Vawter" on Justia Law