At probation revocation hearing, trial court is not required to ask a defendant if he wants to make a statement, but must allow one to be made if requested.
Criminal
State v. Brown, No. 49S05-1606-CR-00348, __ N.E.3d __ (Ind., March 2, 2017).
Brief detainment at a sobriety checkpoint does not entitle defendant to Miranda warnings.
Pena-Rodriguez v. Colorado, No. 15–606, __ US __ (March 6, 2017)
When a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the trial court must consider the evidence of the juror’s statement and any resulting denial of the jury trial guarantee.
Sams v. State, No. 67A01-1604-CR-814, __ N.E.3d __ (Ind. Ct. App., Feb. 21, 2017).
Where an item searched would not have been the target of a well-regulated inventory search, and would not have been searched at all but for the criminal suspicions of the searching officer, the search is pretextual and unreasonable and an item discovered is inadmissible.
Brantley v. State, No. 49A04-1606-CR-1401, __ N.E.3d __ (Ind. Ct. App., Feb. 24, 2017).
State must prove beyond a reasonable doubt that defendant acted under sudden heat to sustain a conviction for voluntary manslaughter.