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Case Clips

Published by the Indiana Office of Court Services

Boyd v. State, No. 25A-CR-2071, __ N.E.3d __ (Ind. Ct. App., Aug. 5, 2026).

August 10, 2026 Filed Under: Criminal Tagged With: Appeals, P. Mathias

Where a human law enforcement officer lacks probable cause to enter a vehicle to search, there is no reason why a canine officer should be permitted to enter a vehicle to search, whether that entry is instinctive or not.

Watters v. State, No. 25A-CR-3310, __ N.E.3d __ (Ind. Ct. App., Jul. 31, 2026).

August 3, 2026 Filed Under: Criminal Tagged With: Appeals, E. Tavitas, P. Felix

When a defendant in the probation context wants to waive counsel, the record must show that the probationer was made aware of the nature, extent, and importance of the right to counsel as well as the necessary consequences of waiving such a right.

Rokita, Indiana Attorney General v. Berry Global Group, and Haitian Center of Evansville, No. 25A-MI-2817, __ N.E.3d __ (Ind. Ct. App., Jul. 27, 2026).

July 27, 2026 Filed Under: Civil Tagged With: Appeals, N. Vaidik

Indiana Code section 4-6-3-3 authorizes our attorney general to issue an “investigative demand”—commonly referred to as a “civil investigative demand,” or “CID.” However, there must be an investigation otherwise the CID is unenforceable.

Parksey v. State, No. 25A-PC-2268, __ N.E.3d __ (Ind. Ct. App., Jul. 6, 2026).

July 6, 2026 Filed Under: Criminal Tagged With: Appeals, R. Altice

Mandatory lifetime parole is a direct, as opposed to collateral, consequence of a plea to voluntary manslaughter and that a defendant is entitled to be advised regarding this consequence before pleading guilty.

State v. Gomez, No. 25S-CR-14, __ N.E.3d __ (Ind., Jun. 30, 2026).

July 6, 2026 Filed Under: Criminal Tagged With: L. Rush, M. Massa, Supreme

Indiana Code § 1-1-2-4 is an interpretive “reference statute” that must be read together with the predicate offense statute, and that when the predicate statute uses only a general reference like “a felony,” the State need only allege a prior felony conviction (including an out-of-state felony) without proving the foreign offense is “substantially similar” to an Indiana felony.

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Case Clips is a weekly publication of the Indiana Office of Court Services featuring appellate opinions curated by IOCS staff for Indiana judges.

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