Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Indiana

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After a jury trial, Defendant was convicted of murder, murder in the perpetration of criminal deviate conduct, and related crimes. The State sought a sentence of life without parole, but in the penalty phase, the jury was unable to reach a unanimous verdict as to whether the State had proven its charged aggravating circumstance. Nonetheless, the trial court sentenced Defendant to life imprisonment without the possibility of parole on the murder count. The Supreme Court remanded for a revised sentencing order as to the judge’s conclusion that life imprisonment was the appropriate sentence. On remand, the trial court affirmed the sentence. Defendant appealed, arguing, on grounds not previously raised, that the trial court’s imposition of a life sentence violated the Sixth Amendment because the aggravating factor supporting the sentence was not determined by the trier of fact during the penalty phase. The Supreme Court agreed, holding that the trial court committed reversible error by imposing a sentence of life without parole under the circumstances. In the interests of judicial economy, the Court further exercised its appellate prerogative to sentence Defendant to a term of years. View "Lewis v. State" on Justia Law

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After a jury trial, Defendant was convicted of murder, robbery, and conspiracy to commit robbery. Defendant was sentenced to life imprisonment without possibility of parole. Defendant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) Defendant was not denied due process in discovery; (2) Defendant was not denied his right to a speedy trial; (3) the trial court did not abuse its discretion in denying Defendant’s requests to hire DNA and blood spatter experts at public expense; (4) the trial court did not commit fundamental error by allowing unknown witnesses to remain in the courtroom during opening statements despite a separation order; (5) the trial court did not abuse its discretion by allowing the State’s entomologist to testify; (6) the trial court properly admitted evidence found in Defendant’s van; and (7) sufficient evidence supported Defendant’s convictions. View "Griffith v. State" on Justia Law

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Defendant was arrested and charged with several drug-related offenses. Defendant filed a motion to suppress all evidence seized as a result of a search of his home conducted without a warrant. The trial court largely denied the motion. After a jury trial, Defendant was found guilty of four drug-related counts. On appeal, Defendant argued that the police made a warrantless entry into his home without valid consent and that the police conducted an illegal protective sweep once inside. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress all evidence seized in the search of his home, holding (1) under the circumstances of this case, Defendant’s house guest, who answered the door to Defendant’s home, did not have the apparent authority to consent to police entry; and (2) because the police did not have a warrant or warrant exception to justify entry into Defendant’s home, the subsequent searches, including the protective sweep, were unlawful, and the fruits of those searches must be suppressed. View "Bradley v. State" on Justia Law

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Defendant was charged with operating a vehicle with an alcohol concentration equivalent (ACE) of 0.08 or more. At trial, the judge instructed the jury to presume Defendant’s ACE at the time of the offense based on a chemical test that was performed within three hours of his being stopped by law enforcement. The instruction told the jury it “shall presume,” yet also stated that “the presumption is rebuttable.” Defendant appealed, arguing that the instruction amounted to fundamental error because it improperly relieved the State of its burden to prove each element beyond a reasonable doubt. The Court of Appeals agreed and reversed Defendant’s conviction, concluding that the instruction did not make clear that the presumption was merely permissible. The Supreme Court granted transfer, thus vacating the opinion below, and affirmed, holding that the instruction did not unconstitutionally shift the State’s burden of proof in violation of Defendant’s due process rights. View "Pattison v. State" on Justia Law

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Thomas Hale appealed his conviction for dealing in methamphetamine, on the sole grounds that the trial court abused its discretion in failing to grant him, at public expense, depositions of two State’s witnesses. After review, the Indiana Supreme Court found that prior precedent compelled the Court to agree with Hale and reverse his conviction. The Court took the opportunity of this case to provide guidance as to how trial courts should address such motions in the future. View "Hale v. Indiana" on Justia Law

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Defendant was charged with two D-felony counts of strangulation and two counts of domestic battery, one of which was elevated to a D-felony based on a prior domestic battery conviction. Defendant moved to bifurcate the D-felony domestic battery charge. The jury found Defendant guilty of the misdemeanor domestic battery and not guilty of the strangulation charges. The judge then asked Defendant’s counsel whether Defendant would like to waive his right to a jury trial on the D-felony domestic battery charge. Defendant remained silent while his attorney told the judge that Defendant intended to proceed as a bench trial on the second phase of the bifurcated trial. After a bench trial on the second phase Defendant was found guilty of the D-felony domestic battery. Defendant appealed, arguing that he did not validly waive his state and federal constitutional jury trial rights. The Supreme Court reversed Defendant’s conviction for D-felony domestic battery, holding that the trial court committed fundamental error by proceeding to trial absent personal waiver of his constitutional jury trial right by Defendant himself. Remanded for a new trial. View "Horton v. State" on Justia Law

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After a jury trial, Defendant was found guilty of battery as a class A misdemeanor. Under the provisions of Ind. Code 35-38-1-7.7(a), the trial court also determined that Defendant committed a crime of “domestic violence,” which determination rendered Defendant ineligible to possess a firearm. Defendant appealed, arguing, in part, that the firearm restriction amounted to additional punishment above the statutory maximum for misdemeanor battery, and because the facts supporting the enhancement were not submitted to a jury, the determination violated Defendant’s Sixth Amendment right to trial by jury. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to trial by jury; and (2) the evidence was sufficient to sustain the determination that Defendant committed a crime of domestic violence. View "Hitch v. State" on Justia Law

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In 2005, Indianapolis passed a non-smoking ordinance (“Ordinance”) banning smoking in public businesses but providing certain exemptions. A 2012 amendment removed the exemption for bars and taverns that had liquor licenses and neither served nor employed anyone under the age of eighteen. The amendment, however, exempted businesses licensed as satellite gambling facilities by April 1, 2012. Plaintiffs, certain bars and restaurants, claimed the Ordinance violated the Equal Privileges and Immunities Clause of the Indiana Constitution because it applied to them but exempted satellite gambling facilities. The trial court granted summary judgment for Defendants, concluding that the Ordinance’s exemptions were not unconstitutional. The Court of Appeals reversed and severed the satellite facility exemption, concluding that the Ordinance’s exemption for satellite facilities violated the Equal Privileges and Immunities Clause. The Supreme Court granted transfer and affirmed the trial court’s grant of summary judgment in favor of the City, holding that the Ordinance does not violate the Indiana Constitution’s Equal Privileges and Immunities Clause because the exemption for satellite gambling facilities is reasonably related to the inherent differences distinguishing satellite gambling facilities from bars and restaurants and because the Ordinance does not create a monopoly or treat similarly situated classes disparately. View "Whistle Stop Inn, Inc. v. City of Indianapolis" on Justia Law

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In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

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In 2013, Defendant was charged with second degree murder for the death of a toddler that occurred in 1977. During a bench trial, the court admitted into evidence an autopsy report. The autopsy was performed by a pathologist who was unavailable to testify at trial. In addition to the autopsy report, the State called a forensic pathologist to testify regarding his independent opinion of the child’s death and injuries based on the autopsy report. The trial court found Defendant guilty of second degree murder. Defendant was sentenced to life imprisonment under the relevant sentencing statutes in 1977. The Supreme Court affirmed, holding (1) because the autopsy report was not testimonial, Defendant’s confrontation right was not violated when the report was admitted into evidence or when the surrogate pathologist testified regarding the information detailed in the autopsy report; (2) the delay between the murder of the child and Defendant’s prosecution did not violate Defendant’s due process rights; and (3) even if the trial court erred at sentencing by taking into consideration the current sentencing scheme that was inapplicable in this case, the error was harmless. View "Ackerman v. State" on Justia Law