Distinct evidence supported convictions for attempted promotion of human trafficking and criminal confinement; convictions therefore did not violate double jeopardy.
Criminal
Rodgers v. State, No. 20A03-1412-CR-438, ___ N.E.3d ___ (Ind. Ct. App., Aug. 7, 2015).
Court could not order defendant to participate in victim-offender reconciliation program (VORP) without his agreement.
Bryant v. State, No. 90A04-1501-CR-11, ___ N.E.3d ___ (Ind. Ct. App., Aug. 7, 2015).
In prosecution for receiving stolen property, county where the property was stolen was a proper venue, regardless of whether defendant knew where the theft occurred.
Williams v. State, No. 35A02-1412-PC-864, ___ N.E.3d ___ (Ind. Ct. App., Aug. 7, 2015).
Even if defendant’s paraphernalia conviction could not support HSO enhancement under pre-2014 criminal code, he was not entitled to PCR; he benefited from the guilty plea that included the enhancement and would have pleaded guilty anyway.
McElfresh v. State, No. 32A01-1411-CR-514, ___ N.E.3d ___ (Ind. Ct. App., Aug. 7, 2015).
Defendant’s letter to victim’s mother, truthfully stating that victim could face legal consequences for lying under oath in his case, did not support conviction for attempted obstruction of justice. And because his letter did not actually reach the victim in violation of no-contact order, it could not support invasion of privacy but only lesser-included offense of attempted invasion of privacy.