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.
Criminal
Parksey v. State, No. 25A-PC-2268, __ N.E.3d __ (Ind. Ct. App., Jul. 6, 2026).
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).
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.
Monroe v. State, No. 26S-CR-208, __ N.E.3d __ (Ind., Jun. 29, 2026).
Tumulty’s bar on direct appeals from guilty pleas applies to double-jeopardy challenges to convictions entered on a guilty plea, so the defendant generally must proceed via post-conviction relief rather than a direct appeal. But a defendant may obtain direct appellate review by moving to withdraw the guilty plea as to the lesser-included offense (and asking the trial court to vacate that conviction) and then appealing the denial of that motion.
Ramos-Osario v. State, No. 26S-CR-198, __ N.E.3d __ (Ind., Jun. 24, 2026).
While judges can reconsider pretrial suppression rulings, the State is not required to prove constitutional compliance a second time at trial.