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Case Clips

Published by the Indiana Office of Court Services

Criminal

White v. State, No. 24A-CR-2592, __ N.E.3d __ (Ind., June 25, 2025).

June 30, 2025 Filed Under: Criminal Tagged With: Appeals, P. Felix, P. Mathias

Our Supreme Court’s double jeopardy analysis in Powell applies where the question is whether the State has alleged or shown discrete, prosecutable acts under identical statutory language, and our Supreme Court’s analysis in Wadle applies where the question is whether the State has alleged or used the same evidence to show violations of different statutory language. However, in certain circumstances, both Wadle and Powell may apply.

Peters v. Quakenbush, No. 25S-PL-152, __ N.E.3d __ (Ind., June 19, 2025).

June 23, 2025 Filed Under: Civil, Criminal Tagged With: C. Goff, D. Molter, G. Slaughter, Supreme

If a person “is required to register as a sex or violent offender in any jurisdiction,” that person must “register for the period required by the other jurisdiction or the period described in this section, whichever is longer.” I.C. § 11-8-8-19(f). This applies to a person residing, working, or attending school in Indiana even though that person committed no offense in the other jurisdiction that imposed the triggering registration requirement.

Heitz v. State, No. 24A-CR-802, __ N.E.3d __ (Ind., June 6, 2025).

June 9, 2025 Filed Under: Criminal Tagged With: Appeals, L. Weissmann, P. Felix

When a trial court’s local practice conflicts with Criminal Rule 4(C), the local practice is invalid, and delays arising from noncompliance with such practices cannot be charged to defendants.

Maze v. State, No. 24A-CR-2596, __ N.E.3d __ (Ind., May 28, 2025).

June 2, 2025 Filed Under: Criminal Tagged With: Appeals, P. Foley

When determining whether to appoint counsel, trial courts must consider three distinct items—assets, income, and necessary expenses in calculating a defendant’s ability to pay. If the parties fail to provide the information, courts themselves must make inquiries calculated to bring out the necessary evidence.

Qualls v. State, No. 24A-CR-131, __ N.E.3d __ (Ind. Ct. App., May 15, 2025).

May 19, 2025 Filed Under: Criminal Tagged With: Appeals, M. Robb

Unless there is new evidence or information discovered to warrant additional charges, the potential for prosecutorial vindictiveness is too great for courts to allow the State to bring additional charges against a defendant who successfully moves for a mistrial, thus creating the presumption of prosecutorial vindictiveness.

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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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