The eggshell doctrine can be used in criminal cases, including murder. The eggshell skull doctrine is one of causation, and causation is a required element in proving a criminal conviction, it only makes sense that the doctrine be applied for such purposes.
JQR v. State, No. 24S-JV-298, __ N.E.3d __ (Ind., March 12, 2025).
Trial court abused its discretion by admitting a juvenile’s statements into evidence without a valid waiver of right. An adverse interest may arise if the evidence shows an adult waives the juvenile’s rights but stands to personally benefit from the waiver to the child’s detriment.
In re W.H., No. 24A-JC-2241, __ N.E.3d __ (Ind. Ct. App., March 7, 2025).
Because the court was required to order preparation of a predispositional report in a CHINS case, and the report had to be provided to the parties prior to the dispositional hearing, the report did not need to be admitted into evidence to be part of the record that the juvenile court could consider.
JWB v. State, No. 24S-CR-288, __ N.E.3d __ (Ind., Feb. 24, 2025).
Even if the recent amendments to Ind. Code 31-30-1-4(d) and 31-37-1-2 (the juvenile jurisdiction statutes), are remedial, the General Assembly did not intend to apply them retroactively to pending cases.
Tingley v. First Financial Bank, No. 24S-PL-299, __ N.E.3d __ (Ind., Feb. 25, 2025).
Venue statutes do not remove or alter a court’s subject-matter jurisdiction, which is separate and distinct from a trial court’s consideration of prudential matters.