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Case Clips

Published by the Indiana Office of Court Services

E. Tavitas

A.R. v. State, No. 22A-JV-156, __ N.E.3d __ (Ind. Ct. App., Oct. 5, 2022).

October 11, 2022 Filed Under: Criminal, Juvenile Tagged With: Appeals, E. Tavitas, P. Riley

While Ind. Code § 31-30-2-3, states that the trial court, on its own motion, may reinstate a jurisdiction over a juvenile after release from DOC, a motion by the prosecution is sufficient. Moreover, Ind. Code § 11-8-8-4.5, which subjects an offender who is at least 14 years age to sex offender registration, applies at the time of registration, not when the delinquent act was committed.

Hayko v. State, No. 21A-CR-2407, __ N.E.3d __ (Ind. Ct. App., Sep. 28, 2022).

October 3, 2022 Filed Under: Criminal Tagged With: Appeals, E. Tavitas, J. Baker

Ind. Rule of Evid. 608 sets forth two types of evidence; opinion and reputation. In contrast to reputation evidence, opinion testimony is admissible if rationally based on the witness’s perception and helpful to a clear understanding of the witness’s testimony or to a determination of a fact in issue.

Holmgren v. State, No. 21A-CR-2756, __ N.E.3d __ (Ind. Ct. App., Sept. 30, 2022).

October 3, 2022 Filed Under: Criminal Tagged With: Appeals, E. Tavitas

To receive an increased sentence under Ind. Code § 35-50-2-4(c) for Level 1 felony child molesting, Apprendi mandates that a victim’s age is a fact that must be determined by the fact-finder.

Parker v. State, No. 21A-CR-1643, __ N.E.3d __ (Ind. Ct. App., Aug. 30, 2022).

September 26, 2022 Filed Under: Criminal Tagged With: Appeals, E. Tavitas

A defendant cannot avail himself the rulings in another case involving another party in his own criminal case. There must be an identity of parties or their privies and mutuality of estoppel for another ruling to have preclusive effect in a criminal case.

J.L. v. M.M., No. 22A-PO-512, __ N.E.3d __ (Ind. Ct. App., Sept. 6, 2022).

September 12, 2022 Filed Under: Civil Tagged With: Appeals, E. Tavitas

The protection order statutes should not be used as a de facto method to modify custody and/or parenting time. However, the protection order statutes offer expedited and ex parte proceedings to provide a “stop gap” to stabilize the situation until the trial court can determine the best interests of the child in a modification proceeding.

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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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