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Case Clips

Published by the Indiana Office of Court Services

M. Massa

State v. Gomez, No. 25S-CR-14, __ N.E.3d __ (Ind., Jun. 30, 2026).

July 6, 2026 Filed Under: Criminal Tagged With: L. Rush, M. Massa, Supreme

Indiana Code § 1-1-2-4 is an interpretive “reference statute” that must be read together with the predicate offense statute, and that when the predicate statute uses only a general reference like “a felony,” the State need only allege a prior felony conviction (including an out-of-state felony) without proving the foreign offense is “substantially similar” to an Indiana felony.

Wike, et al. v. Grandview Solar Project, et. al., No. 26S-PL-192, __ N.E.3d __ (Ind., Jun. 24, 2026).

June 29, 2026 Filed Under: Civil Tagged With: C. Goff, M. Massa, Supreme

Normally, challenges to a board of zoning appeals’ decision need to be brought within 30 days of the decision. But Indiana recognizes the ultra vires doctrine, which, applied here, says some board of zoning appeals’ actions might be void, meaning they are vulnerable to a lawsuit at any time, even long after the normal window for review has closed.

Tillett v. State, No. 25S-CR-231, __ N.E.3d __ (Ind., Apr. 24, 2026).

April 27, 2026 Filed Under: Criminal Tagged With: C. Goff, M. Massa, Supreme

Under Indiana Code Section 35-36-2-1, a defendant in a felony case must file a notice of intent to assert an insanity defense no later than 20 days before the omnibus date, or 10 days before the omnibus date for misdemeanor charges. However, in the interest of justice and upon a showing of good cause, the court may permit the filing to be made at any time before commencement of the trial.

Brooks v. USA Track & Field, Inc., No. 25S-PL-103, __ N.E.3d __ (Ind., Dec. 17, 2025).

December 22, 2025 Filed Under: Civil Tagged With: C. Goff, M. Massa, Supreme

A party cannot amend their complaint after final judgment has been issued. T.R. 15(A) does not apply once a final judgment has been entered.

Elzey v. State, No. 24S-CR-436, __ N.E.3d __ (Ind., Nov. 20, 2025).

November 24, 2025 Filed Under: Criminal Tagged With: L. Rush, M. Massa, Supreme

The Indiana State Public Defender must represent all indigent individuals who are confined in a penal facility in Indiana or committed to the Department of Correction due to a criminal conviction or delinquency adjudication. However, the Public Defender Statute, I.C. 33-40-1-2, and our post-conviction rules specifically Post-Conviction Rule 1(9)(a), still enable SPD to exercise its discretion in agreeing to representation.

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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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