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 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

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The Supreme Court reversed the judgment of the trial court granting Defendant's motion to suppress evidence seized during the search of his home, holding that a waiver of the "right against search and seizure" clearly informs the defendant that a search may be conducted without reasonable suspicion.When a defendant is processed for home detention, he normally signs an agreement in which he forgoes many of his rights. The agreement typically includes consent to allow community corrections to search the defendant's person or home to ensure compliance with the rules. Defendant in this case argued that the search of his home violated his Fourth Amendment rights because the contract he signed when he was placed on home detention didn't include a waiver of searches without reasonable suspicion. The trial court granted the motion to suppress. The Supreme Court reversed, holding that the contract unambiguously informed Defendant that he waived his right against search and seizure absent reasonable suspicion. View "State v. Ellis" on Justia Law

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The Supreme Court reversed the judgment of the trial court reversing the order of the City of Bloomington Board of Zoning Appeals (BZA) affirming the decision of the City of Bloomington citing UJ-Eighty Corporation for a zoning violation, holding that there were not constitutional violations in this case.UJ-Eighty owned a fraternity house at Indiana University (IU) in Bloomington that was located within a district zoned by the City to permit limited residential uses. UJ-Eighty leased its house to an IU-sanctioned fraternity, but before the lease ended, IU revoked its recognition and approval of the fraternity, which meant that no one could live there. Bloomington cited UJ-Eighty for a zoning violation when two residents remained in the house. The BZA affirmed. UJ-Eighty appealed, arguing that the City impermissibly delegated its zoning authority to IJ by allowing it unilaterally to define fraternities and sororities. The trial court agreed and struck down the ordinance's definition of fraternities and sororities under the state and federal constitutions. The Supreme Court reversed, holding that Bloomington did not violate the Fourteenth Amendment because the ordinance was not an impermissible delegation of power or a denial of due process. View "City of Bloomington Board of Zoning Appeals v. UJ-Eighty Corp." on Justia Law

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The Supreme Court reversed the judgment of the trial court denying Defendant's motion to dismiss the State's habitual-offender allegation and remanded with instructions to vacate Defendant's habitual-offender enhancement, holding Defendant's constitutional right to a speedy trial was violated by a six-plus-year delay.Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual-offender enhancement. More than six years passed before the State retried the habitual-offender allegation. Defendant filed a motion to dismiss, but the trial court denied the motion, eventually finding Defendant to be a habitual offender. The Supreme Court reversed, holding (1) Criminal Rule 4(C) does not apply to a habitual-offender retrial; but (2) Defendant's right to a speedy trial was violated, and therefore, Defendant was entitled to relief. View "Watson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of the murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct and that, under the circumstances, Defendant did not demonstrate that the misconduct probably harmed him.After Defendant was convicted, he filed a motion to set aside the verdict based on juror misconduct, alleging that one juror, L.W., falsely answered the juror questionnaire. The juror wrote "N/A," meaning not applicable, in response to questions about the jurors past criminal history and whether she had been a victim of a crime, when those answers should have been a yes. The trial court denied Defendant's motion to set aside the verdict. The Supreme Court affirmed, holding (1) juror L.W. committed gross misconduct; but (2) despite the gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of dealing in a look-a-like substance, a Level 5 felony under Ind. Code 35-348-4-4.6, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant offered to sell a substance to a strange at a casino, and the incident was captured by video surveillance. A gaming enforcement agent took Defendant to an interview room, patted him down, and found packaged drugs. Defendant moved to suppress the evidence stemming from the pat-down. The trial court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that the search and seizure proceeded within the bounds of the Fourth Amendment, and therefore, the trial court did not err in denying Defendant's motion to suppress. View "Johnson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court finding a statute stopping the City of Bloomington's proposed annexation of several areas of land and prohibiting the City from attempting to annex the areas for five years unconstitutional, holding that the statute is unconstitutional special legislation in violation of Ind. Const. art. IV, 23.While Bloomington was taking steps toward annexation, the General Assembly passed Ind. Code 36-4-3-11.8 cutting off the City's proposed annexation and prohibiting the City from trying to annex the same areas for the next five years. The City sought declaratory and injunctive relief. The trial court granted summary judgment for the City, declaring the statute unconstitutional under Article 4, Sections 19 and 23 of the Indiana Constitution. The Supreme Court affirmed, holding (1) the City can bring this declaratory judgment action against the Governor; and (2) section 11.8 is unconstitutional special legislation. View "Holcomb v. City of Bloomington" on Justia Law

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The Supreme Court affirmed the judgment of the trial court in this declaratory judgment action against Governor Holcomb, holding that the statute passed by the legislature in 2017 stopping the City of Bloomington's proposed annexation of several areas of land and prohibiting the City from trying to annex the areas for five years is unconstitutional special legislation in violation of Ind. Const. art. IV, 23.In 2017, the Bloomington mayor announced plans for a proposed annexation of several areas of land. After the City Council adopted the initiating resolutions and Bloomington took its initial steps toward annexation, the General Assembly passed legislation codified at Ind. Code 36-4-3-11.8 cutting off Bloomington's proposed annexation and prohibiting the City from trying to annex the same areas for the next five years. The City brought this suit seeking declarations that section 11.8 constitutes unconstitutional special legislation and violates article 4, section 19's single-subject rule. The trial court declared section 11.8 unconstitutional under article 4, sections 19 and 23 of the Indiana Constitution. The Supreme Court affirmed, holding that section 11.8 constitutes impermissible special legislation. View "Holcomb v. City of Bloomington" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of "dealing in a look-a-like substance," a level five felony under Ind. Code 35-48-4-4.6, holding that trial court did not err in denying Defendant's motion to suppress.At a casino, Defendant offered to sell a substance to a stranger, who reported the incident. Thereafter, a Gaming Enforcement Agent led Defendant to an interview room and proceeded to pat him down. The trial court admitted the evidence discovered as a result of the pat down. The Supreme Court affirmed, holding (1) the search and seizure proceeded within the bounds of the Fourth Amendment; and (2) therefore, the trial court did not abuse its discretion in admitting evidence obtained as a result. View "Johnson v. State" on Justia Law