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Case Clips

Published by the Indiana Office of Court Services

Appeals

McElfresh v. State, No. 32A01-1411-CR-514, ___ N.E.3d ___ (Ind. Ct. App., Aug. 7, 2015).

August 14, 2015 Filed Under: Criminal Tagged With: Appeals, J. Baker

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.

Gavin v. State, No. 79A02-1501-CR-27, ___ N.E.3d ___ (Ind. Ct. App., Aug. 11, 2015).

August 14, 2015 Filed Under: Criminal Tagged With: Appeals, N. Vaidik

Shooting suspect’s statement that his gun was in his car was admissible under public-safety exception to Miranda; police feared that suspect’s 3-year-old child, who was also in the car, might get to the gun.

Taylor v. Taylor, No. 49A04-1502-DR-58, __ N.E.3d __ (Ind. Ct. App., Aug. 13, 2015).

August 14, 2015 Filed Under: Civil Tagged With: Appeals, E. Najam, J. Baker

“[A]fter a relocation notice is filed, if a party seeks a modification of an existing child support order that party must also file a petition to modify child support.”

Akins v. State, No. 49A02-1412-CR-869, ___ N.E.3d ___ (Ind. Ct. App., July 31, 2015).

August 7, 2015 Filed Under: Criminal Tagged With: Appeals, C. Darden

Restitution award was abuse of discretion; there was no evidence that the injury for which restitution was sought was caused by, or even connected with, the defendant.

Smart v. State, No. 29A02-1412-CR-887, ___ N.E.3d ___ (Ind. Ct. App., Aug. 4, 2015).

August 7, 2015 Filed Under: Criminal Tagged With: Appeals, M. Barnes

Defendant’s admission to injecting “methamphetamine,” without more, was insufficient to prove that he injected the legend drug “methamphetamine hydrochloride”; there was no evidence or basis for judicial notice that the two substances were the same

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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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