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Case Clips

Published by the Indiana Office of Court Services

Criminal

Kelly v. State, No. 23A-CR-1805, __ N.E.3d __ (Ind. Ct. App., Jan. 10, 2024).

January 16, 2024 Filed Under: Criminal Tagged With: Appeals, M. May

A trial court has discretion to deny a defendant’s motion to replace counsel during or immediately before trial.

Stone v. State, No. 23A-CR-625, __ N.E.3d __ (Ind. Ct. App., Jan. 12, 2024).

January 16, 2024 Filed Under: Criminal Tagged With: Appeals, T. Crone

Convictions based on the same subsection of the rape statute that are mutually exclusive criminal acts — forcible sexual intercourse and forcible other sexual conduct — do not violate double jeopardy.

Hoback v. State, No. 23A-CR-411, __ N.E.3d __ (Ind. Ct. App., Dec. 20, 2023).

December 29, 2023 Filed Under: Criminal Tagged With: Appeals, M. Bailey, P. Felix

Pursuant to C.R. 4, when docket entries are absent or missing regarding the reason for a delay, the delay is not chargeable to the defendant.

Sloan v. State, No. 22A-CR-2250, __ N.E.3d __ (Ind. Ct. App., Dec. 29, 2023).

December 29, 2023 Filed Under: Criminal Tagged With: Appeals, M. Robb

A probable cause affidavit need not exclude every hypothesis of innocence to establish sufficient probable cause for the warrant; rather, it only needs to demonstrate to the issuing judge that, given all the circumstances, there was a fair probability that evidence of a crime would be found in a particular place. Moreover, facts establishing illegal internet activity associated with a particular IP address, and assignment of the IP address at the time in question to a particular internet subscriber at a specific physical address, provide a nexus between the illegal activity and the physical address sufficient to establish probable cause for a warrant to search the residence at the physical address.

Kendall v. State, No. 23A-CR-1473, __ N.E.3d __ (Ind. Ct. App., Dec. 29, 2023).

December 29, 2023 Filed Under: Criminal Tagged With: Appeals, E. Brown

The crime of identity deception does not require that the identifying information must coincide with any real person or an existing human being. Additionally, the statute governing identity deception includes elements not contained in the statute governing false informing and thus, does not violate Article 1, Section 16, Indiana’s Proportionality Clause.

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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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