Articles Posted in Supreme Court of Indiana

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The Supreme Court affirmed the judgment of the trial court adjudicating B.T.E. a juvenile delinquent on two counts, including attempted aggravated battery, for plotting to shoot up and blow up his high school, holding that there was sufficient evidence to support the attempted aggravated battery conviction. B.T.E. took several steps to implement his plot to blow up his high school, targeting two of his classmates to die. The trial court adjudicated B.T.E. a delinquent for attempted aggravated battery and conspiracy to commit aggravated battery. On appeal, B.T.E. argued that there was insufficient evidence that he took the required “substantial step” toward committing aggravated battery under Indiana’s criminal-attempt statute, and instead, that his actions were “mere preparation.” The Supreme Court affirmed, holding that B.T.E.’s affirmative conduct amounted to a substantial step toward the commission of aggravated battery. View "B.T.E. v. State" on Justia Law

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The Supreme Court reversed the determination of the trial court finding that R.R., a juvenile, violated his probation and adjudicating him a delinquent for auto theft and false informing, holding that the trial court violated R.R.’s right to be present at the fact-finding hearing by holding hearing in R.R.’s absence. On appeal, R.R. argued that juveniles have a due process right to be present at fact-finding hearings on a delinquency charge and that the trial court violated this right by holding the hearing in his absence. The Supreme Court assumed without deciding that juveniles are entitled to be present at fact-finding hearings and held (1) a juvenile can waive his right to be present at a fact-finding hearing but must do so according to the juvenile waiver-of-rights statute; (2) there was no waiver of R.R.’s right to be present, and therefore, the trial court violated that right by holding the fact-finding hearing in R.R.’s absence; and (3) the absurdity doctrine did not apply to this case. View "R.R. v. State" on Justia Law

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The Supreme Court summarily affirmed the parts of the opinion of the court of appeals that addressed and rejected J.R.’s challenge to a pat-down search and remanded to the juvenile court to vacate the delinquency adjudication for carrying a handgun without a license (CHWOL) and affirmed the delinquency adjudication for dangerous possession of a firearm, as all parties agreed that double jeopardy principles precluded J.R.’s dual adjudications. The juvenile court found sixteen-year-old J.R. delinquent for committing acts that would be dangerous possession of a firearm and CHWOL, had they been committed by an adult. On appeal, J.R. argued that a pat-down search violated his constitutional right to be free from unreasonable searches. The court of appeals concluded that the pat-down search was constitutional but that J.R.’s adjudication for CHWOL should be vacated on double jeopardy grounds. The Supreme Court affirmed. View "J.R. v. State" on Justia Law

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Custodial interrogation for purposes of Miranda v. Arizona, 384 U.S. 436 (1966), at public schools requires police involvement, and so when school officials alone meet with students Miranda warnings are not required. After D.Z. was called into the office of the assistant principal of a high school he confessed to writing sexual graffiti on the school’s boys-bathroom walls. The State filed a delinquency petition alleging that D.Z. committed criminal mischief and harassment. The juvenile court found that D.Z. had committed criminal mischief. The Supreme Court reversed, finding that D.Z.’s statements to the assistant principal should have been suppressed because D.Z. was under custodial interrogation. The Supreme Court vacated the opinion of the court of appeals and affirmed the criminal-mischief adjudication, holding that D.Z. was not entitled to Miranda warnings because he was interviewed only by a school official - not by police. View "D.Z. v. State" on Justia Law

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At issue in this case was when public school students are entitled to Miranda warnings at school. B.A., who was thirteen years old, was escorted from a school bus and questioned in a vice-principal’s office in response to a bomb threat on a bathroom wall. Three officers wearing police uniforms hovered over B.A. and encouraged him to confess. B.A. moved to suppress the evidence from his interview, arguing that he was entitled to Miranda warnings because he was under custodial interrogation and officers failed to secure waiver of his Miranda rights under Indiana’s juvenile waiver statute, Ind. Code 31-32-5-1. The juvenile court denied the motion and found B.A. delinquent for committing false reporting and institutional criminal mischief. The Supreme Court reversed B.A.’s delinquency adjudications, holding (1) B.A. was in police custody and under police interrogation when he made the incriminating statements; and (2) therefore, B.A.’s statements should have been suppressed under both Miranda and Indiana’s juvenile waiver statute. View "B.A. v. State" on Justia Law

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The Supreme Court affirmed T.H.’s adjudication as a delinquent but remanded the case to the trial court to modify its records to show that T.H. committed an act that would be criminal mischief as a Class B misdemeanor. The State filed a petition alleging that T.H. committed a delinquent act that would be criminal mischief, a Class A misdemeanor, if committed by an adult. The trial court found that T.H. committed criminal mischief that caused at least $750 in loss, which would be a Class A misdemeanor, and adjudicated T.H. delinquent. The Supreme Court affirmed the adjudication but remanded the case, holding that no reasonable fact-finder could find the element of loss of at least $750 proven beyond a reasonable doubt. View "T.H. v. State" on Justia Law

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Under Indiana Code section 31-25-2-5, no family case manager at the Indiana Department of Child Services can oversee more than 17 children at a time who are receiving services. The statute does not require the Department to perform any specific, ministerial acts for achieving that number. Price, a family case manager, filed a proposed class action. She alleged that her caseload was 43 children and sought an “order mandating or enjoining [D]efendants to take all necessary steps to comply with [Section 5].” The Indiana Supreme Court affirmed the dismissal of Price’s claim prior to class certification. Judicial mandate is an extraordinary remedy—available only when the law imposes a clear duty upon a defendant to perform a specific, ministerial act and the plaintiff is clearly entitled to that relief. The statute at issue does not impose a specific, ministerial duty. View "Price v. Indiana Department of Child Services; Director of Indiana Department of Child Services" on Justia Law

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J.D.M. was adjudicated a delinquent for committing child molestation which, if committed by an adult, would constitute a Class C felony. The juvenile court ordered placement of J.D.M. at the Wernle Youth and Family Treatment Center. Prior to J.D.M.’s release from Wernle, the juvenile court issued an order that required J.D.M. to register as a sex offender. J.D.M. appealed, arguing that the statutory prerequisites for placing a juvenile on the sex offender registry were not met. The Supreme Court reversed the order requiring J.D.M. to register as a sex offender, holding that the juvenile court could not order J.D.M. to register as a sex or violent offender prior to his discharge from Wernle. Remanded. View "J.D.M. v. State" on Justia Law