The Powell test applies to multiple convictions for elevated offenses that share a common base offense. Stated another way, a base offense and its elevated forms constitute a single statutory offense.
Rodriguez v. State, No. 25A-CR-1789, __ N.E.3d __ (Ind. Ct. App., Mar. 18, 2026).
Pursuant to Indiana Evidence Rule 103, a defendant preserves a continuing objection to the admission of evidence for appellate review simply by making a timely objection to that evidence during trial, identifying the specific ground for the objection, and receiving the trial court’s definitive ruling on the objection on the record at trial.
State v. Watson, No. 25A-CR-1789, __ N.E.3d __ (Ind. Ct. App., Mar. 18, 2026).
Under Indiana law, prior accusations are demonstrably false where the victim has admitted the falsity of the charges or they have been disproved.
Indiana Compensation Rating Bureau and Indiana Department of Insurance v. Technology Insurance Company, No. 26S-PL-83, __ N.E.3d __ (Ind., Mar. 17, 2026).
Whether the Company is entitled to relief rests on two questions: first, whether the Company had to follow the dispute-resolution provisions set out in the Assigned Risk Plan and agreements, limiting the Company’s relief in the trial court to judicial review under the Administrative Orders and Procedures Act; second, assuming the Company is limited to seeking recourse under AOPA, whether the Company properly sought judicial review.
Norris v. Norris, No. 25S-DR-226, __ N.E.3d __ (Ind., Mar. 12, 2026).
After the Court of Appeals issued its published opinion that partially reversed the trial court’s judgment, Jennifer timely sought rehearing. While that request was pending, the trial court, on its own, issued a revised order to implement the Court of Appeals’ instructions. But the trial court lacked authority to issue that order because the appellate opinion was not yet certified. We thus take this opportunity to emphasize the importance of following Appellate Rule 65(E), which prohibits trial courts, administrative agencies, and parties from taking action based on published opinions or memorandum decisions (collectively “opinions”) before they are certified.