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Case Clips

Published by the Indiana Office of Court Services

D. Molter

State v. Lyons, No. 23S-CR-163, __N.E.3d __ (Ind., June 27, 2023).

July 3, 2023 Filed Under: Criminal Tagged With: D. Molter, Supreme

Before excluding evidence as a Trial Rule 37 discovery sanction, a trial court must find that the exclusion is the sole remedy available to avoid substantial prejudice, or that the sanctioned party’s culpability reflects an egregious discovery violation.

Harris v. State, No. 23S-CR-165, __N.E.3d __ (Ind., June 29, 2023).

July 3, 2023 Filed Under: Criminal Tagged With: C. Goff, D. Molter, G. Slaughter, L. Rush

The jury in a habitual offender proceeding must be allowed to make the ultimate legal determination of whether the defendant has the status of habitual offender. Only evidence of the defendant’s alleged convictions is relevant to that determination. A defendant has no constitutional right to present irrelevant evidence.

Med. Licensing Bd. of Ind. v. Planned Parenthood Great Northwest, No. 22S‐PL‐338, __N.E.3d __ (Ind., June 30, 2023).

July 3, 2023 Filed Under: Civil Tagged With: C. Goff, D. Molter, G. Slaughter, Supreme

Abortion providers have standing to contest the constitutionality of Senate Bill 1 (2022) because the statute criminalizes their work, and so they face the sort of imminent, direct, personal injury. Indiana Constitution’s Article 1, Section 1 protects a woman’s right to an abortion that is necessary to protect her life or to protect her from a serious health risk, but the General Assembly retains broad legislative discretion for determining whether and the extent to which to prohibit abortions. The Court reversed the trial court’s preliminary injunction.

Davis v. State, No. 22S-CR-253, __ N.E.3d __ (Ind., May 3, 2023).

May 8, 2023 Filed Under: Criminal Tagged With: C. Goff, D. Molter, Supreme

If a defendant wishes to challenge their guilty plea, they cannot do so through a direct appeal; the issue of whether a defendant’s guilty plea was knowing and voluntary should instead be pursued by filing a petition for post-conviction relief.

M.H. v. State, No. 22S-JV-251, __ N.E.3d __ (Ind., April 19, 2023).

April 24, 2023 Filed Under: Juvenile Tagged With: C. Goff, D. Molter, G. Slaughter, Supreme

When a decision implicates a new jurisdictional rule, as in K.C.G. v. State, courts are to apply the principle of non-retroactivity, rather than vacate a final judgment for voidness, unless the jurisdictional error compromised the reliability or fairness of the proceedings.

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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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