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Case Clips

Published by the Indiana Office of Court Services

Criminal

Owens v. State, No. 21A-CR-1900, __ N.E.3d __ (Ind. Ct. App., March 28, 2023).

April 3, 2023 Filed Under: Criminal Tagged With: Appeals, L. Weissmann

The criminal code demonstrates our legislature’s intent that a habitual offender amendment be filed no less than 30 days before the beginning of trial as opposed to a particular trial setting.

Leshore v. State, No. 23S-CR-51, __ N.E.3d __ (Ind., Feb. 28, 2023).

March 6, 2023 Filed Under: Criminal Tagged With: C. Goff, M. Massa, Supreme

When confronted with a petition under Post-Conviction Rule 2, seeking dispensation from otherwise firm deadlines and their decisive consequences, judges must ask, “was it [Petitioner’s] fault?” And if not, “did [Petitioner] act quickly enough thereafter?” Trial courts should take these questions up in sequence, though a negative answer to either one can be enough to bar relief.

Knowles v. State, No. 22A-CR-2133, __ N.E.3d __ (Ind. Ct. App., Feb. 7, 2023).

February 13, 2023 Filed Under: Criminal Tagged With: Appeals, P. Mathias

Failure to participate in the completion of a presentence investigation report may be punishable by indirect, rather than direct contempt.

Eminger v. State, No. 22A-CR-1077, __ N.E.3d __ (Ind. Ct. App., Feb. 10, 2023).

February 13, 2023 Filed Under: Criminal Tagged With: Appeals, P. Mathias

Any issue which was raised by, or could have been raised by, a timely motion to correct error and timely direct appeal may not be subject of motion for relief from judgment.

Means v. State, No. 23S-CR-26, __ N.E.3d __ (Ind., Feb. 1, 2023).

February 7, 2023 Filed Under: Criminal Tagged With: D. Molter, Supreme

After the Court of Appeals accepts a discretionary interlocutory appeal, it may later dismiss the appeal on non-jurisdictional grounds, although its general reluctance to do so is appropriate. In addition, orders in limine are eligible for discretionary interlocutory review.

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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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