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Case Clips

Published by the Indiana Office of Court Services

C. Goff

State v. Diego, 21S-CR-285, __ N.E.3d __ (Ind., June 9, 2021).

June 14, 2021 Filed Under: Criminal Tagged With: C. Goff, S. David, Supreme

Police may not interrogate a person in custody without proper Miranda warnings or else the State risks having those custodial statements suppressed in a criminal trial. However, not every station house interview implicates Miranda. Miranda warnings are only required when a person is in custody; when a person’s’ freedom of movement is curtailed to a level associated with formal arrest and when he or she is under the same inherently coercive pressures in the police station as those at issue in Miranda v. Arizona.

Combs v. State, 20S-CR-616, __ N.E.3d __ (Ind., June 3, 2021).

June 7, 2021 Filed Under: Criminal Tagged With: C. Goff, G. Slaughter, M. Massa, Supreme

The plain view exception to the warrant requirement may justify the seizure of a vehicle believed to be the fruit, instrumentality, or evidence of a crime provided that police are lawfully in a position from which to view the vehicle, its incriminating character is immediately apparent, and police have a lawful right of access to the vehicle.

Wright v. State, 20S-LW-260, __ N.E.3d __ (Ind., May 4, 2021).

May 11, 2021 Filed Under: Criminal Tagged With: C. Goff, G. Slaughter

When deciding whether a defendant properly waives the right to counsel in capital and LWOP cases, a trial court should frame its waiver inquiry with the state’s heightened reliability interests in mind. That inquiry should focus on whether, and to what extent, the defendant has prior experience with the legal system; the scope of the defendant’s knowledge of criminal law, legal procedures, rules of evidence, and sentencing; and whether and to what extent the defendant can articulate and present any possible defenses, including lesser-included offenses and mitigating evidence.

State v. Ellis, 21S-CR-159, __ N.E.3d __ (Ind., April 26, 2021).

April 26, 2021 Filed Under: Criminal Tagged With: C. Goff, Supreme

When a defendant is processed for home detention, a waiver of the “rights against search and seizure” clearly encompasses the right to be free from search and seizure absent reasonable suspicion.

In re Adoption of I.B., No. 21S-AD-90, __ N.E.3d __ (Ind., March 2, 2021).

March 8, 2021 Filed Under: Civil Tagged With: C. Goff, Supreme

Mother’s consent for adoption was not required when mother failed for one year (1) to significantly communicate with child without justification or (2) to support child when able to do so and required by law.

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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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