Justia Constitutional Law Opinion Summaries

The Supreme Court overruled Salter v. State, 906 N.E.2d 2012 (Ind. Ct. App. 2009), which found Ind. Code 35-49-3-3(a)(1) (the Dissemination Statute) void for vagueness was applied because the intended recipient met Indiana’s age of consent to sexual activity.Defendant in this case was charged with dissemination of matter harmful to minors under the Dissemination Statute for sending a photograph of his erect penis to a sixteen-year-old girl. Defendant moved to dismiss on constitutional grounds, arguing that the statute was void for vagueness. The trial court dismissed the charges, relying on Salter. The Supreme Court reversed and remanded for further proceedings, holding that the Dissemination Statute is not unconstitutionally vague. View "State v. Thakar" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of Class A felony dealing in a narcotic drug. The Court of Appeals reversed Defendant’s conviction, concluding that the police violated his Fourth Amendment rights when they detained and transported Defendant to the police station to await a search warrant and that the trial court erred in not excluding evidence obtained during that detention. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and affirmed the trial court’s decision to admit the disputed evidence, holding (1) police officers had probable cause to believe Defendant was in possession of narcotics; and (2) therefore, transporting Defendant to, and detaining him at, the police station to await the results of a search warrant request did not violate the Fourth Amendment. View "Thomas v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of Class A misdemeanor possession of a handgun with a license, holding that the State’s detention and search of Defendant was unreasonable under Ind. Const. art. I, 11.The court of appeals affirmed Defendant’s conviction, concluding that Defendant’s behavior in evading police in a high crime area was sufficient to give rise to a reasonable suspicion that crime was afoot, especially where the officers believed Defendant was a truant. The Supreme Court vacated the court of appeals’ decision, holding that the police’s investigatory stop, detention, and search of Defendant violated Defendant’s constitutional rights because, although Defendant’s actions were “suspicious,” at the time police moved to detain Defendant, police did not have a reasonable suspicion that he had engaged in or was about to engage in any criminal conduct. View "Jacobs v. State" on Justia Law

The Supreme Court held that evidence obtained after a search and seizure was obtained in violation of the Fourth Amendment and that the trial court erred in denying Defendant’s motion to suppress the evidence obtained as a result of the search and seizure. The trial court denied the motion to suppress, concluding that law enforcement officers had reasonable suspicion to approach and question Defendant after they received a call that someone of Defendant’s description had a handgun on him. The Supreme Court reversed, holding that the intrusion by the police was not reasonable in this case. View "Pinner v. State" on Justia Law

Fifteen years after the Supreme Court affirmed Appellant’s conviction for murder, Appellant filed an amended petition for post-conviction relief, alleging that trial counsel rendered ineffective assistance. The post-conviction court denied relief on the merits. The Supreme Court reversed, holding that, in viewing the evidence without certain inadmissible hearsay statements, Appellant established grounds for relief by a preponderance of the evidence. Specifically, the Court held that counsel’s errors, which allowed the jury to consider the only evidence that identified Appellant as the shooter in determining his guilt or innocence, were sufficient to undermine confidence in the verdict rendered in this case. View "Humphrey v. State" on Justia Law

The Supreme Court held that the “third-party doctrine,” which provides that police are not required to obtain a search warrant to gather information an individual has voluntarily relinquished to a third party, applies as to historical cell-site location information (CSLI). Defendant appealed his convictions on four robbery-related counts, arguing that the State violated his Federal and State Constitutional rights by obtaining historical cell-site location information (CSLI) from his cell-phone service provider and that a detective improperly testified as an expert witness regarding the CSLI. The Supreme Court affirmed, holding (1) under the Fourth Amendment, Defendant had no reasonable expectation of privacy in his cell-phone provider’s historical CSLI; (2) the Indiana Constitution does not prohibit police from taking reasonable actions like obtaining minimally intrusive historical CSLI from a service provider to prevent a criminal suspect from striking again; and (3) the detective sponsoring the CSLI at trial properly testified as a skilled witness. View "Zanders v. State" on Justia Law

Defendant appealed his convictions for two counts of murder for which the trial court imposed consecutive life without parole sentences. The Supreme Court affirmed, holding (1) the evidence was sufficient to sustain the murder convictions; (2) the trial court properly found that the State proved the I.C. 35-50-2-9(b)(11) aggravator beyond a reasonable doubt; (3) the trial court did not abuse its discretion in admitting into evidence Defendant’s recorded phone calls made to a special agent, as the phone calls were not protected by Defendant's Sixth Amendment right to counsel; and (4) Indiana’s life without parole statutory sentencing scheme is constitutional. View "Leonard v. State" on Justia Law

Defendant entered a field sobriety checkpoint and was asked if he had been drinking. Defendant admitted that he had. The officer administered some field sobriety tests and ultimately arrested Defendant. Defendant was charged with operating while intoxicated and operating a vehicle with an alcohol concentration of at least .08 but less than .15 grams of alcohol per 210 liters of breath. During trial, Defendant’s counsel objected to the officer’s testimony about him asking Defendant if he had been drinking and Defendant’s response based on a Miranda violation. In response, the State argued that a Miranda warning was not necessary. The trial court then entered an order suppressing any statements made by Defendant, as well as any evidence obtained thereafter. On appeal, the Court of Appeals, dismissed the appeal, ruling that the State had no statutory authority to appeal because Defendant never filed a written motion to suppress and because the order suppressing the evidence was issued during trial. The Supreme Court granted transfer and reversed the trial court’s suppression order, holding (1) the State may appeal from the trial court’s order granting Defendant’s motion to suppress; and (2) Miranda warnings are not required in circumstances such as these, where a defendant is briefly detained at a public sobriety checkpoint. View "State v. Brown" on Justia Law

Defendant was charged with felony possession. Defendant filed a motion to suppress, arguing that the police violated the Fourth Amendment and Article I, Section 11 of the Indiana Constitution when they opened his car door “to check on [Defendant’s] welfare.” The trial court denied the motion and, after a bench trial, convicted Defendant of misdemeanor possession of cocaine. The court of appeals affirmed, concluding that the police’s act of opening Defendant’s door was constitutionally permissible as a reasonable community caretaking function. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed, holding that the police’s warrantless search of Defendant was constitutionally permissible, as the officer had an objectively reasonable basis to open the door and check on Defendant’s well-being. View "Cruz-Salazar v. State" on Justia Law

Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law