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Case Clips

Published by the Indiana Office of Court Services

N. Vaidik

Marroquin v. Reagle, No. 23A-MI-2545, __ N.E.3d __ (Ind. Ct. App., Feb. 23, 2024).

February 26, 2024 Filed Under: Civil Tagged With: Appeals, N. Vaidik

When defendant was convicted of a crime in Indiana that does not require sex offender registration and then moves to a state that did require sex offender registration, the defendant is not required to register when moving back to Indiana.

Konkle v. State, No. 23A-CR-783, __ N.E.3d __ (Ind. Ct. App., Jan. 24, 2024).

January 29, 2024 Filed Under: Criminal Tagged With: Appeals, C. Bradford, N. Vaidik

The eggshell-skull doctrine does not apply in cases of murder or voluntary manslaughter. The relevant statutes require that the defendant either must intend to kill the victim or know that his actions will likely result in the victim’s death, which is inconsistent with the proposition that you take your victim as you find them.

D.H. v. A.C., No. 23A-JT-1369, __ N.E.3d __ (Ind. Ct. App., Dec. 21, 2023).

December 29, 2023 Filed Under: Juvenile Tagged With: Appeals, N. Vaidik

If a child was conceived as a result of “an act of rape,” the victim-parent can seek to terminate the rights of the perpetrator-parent. “Act of rape” is defined in statute as (1) “an act described in” the rape statute or (2) an act of child molesting (where the victim is under fourteen) involving deadly force, a deadly weapon, serious injury, or drugging.

Owens v. State, No. 23A-CR-985, __N.E.3d __ (Ind. Ct. App., Dec. 11, 2023).

December 11, 2023 Filed Under: Criminal Tagged With: Appeals, N. Vaidik

For a party to invoke T.R. 34 as the basis for an alleged discovery violation, that party must have first made a discovery request. In a criminal case, if the defendant made no discovery request to the State, the defendant cannot later challenge the admission of documents or electronically stored information on the ground that the State violated T.R. 34 in its production of the materials.

Baker v. State, No. 23A-CR-1340, __N.E.3d __ (Ind. Ct. App., Nov. 27, 2023).

November 27, 2023 Filed Under: Criminal Tagged With: Appeals, N. Vaidik

In a criminal jury trial where the State presents evidence of a greater number of separate criminal offenses than charged and does not designate the specific act or acts on which it relies for conviction, a general unanimity instruction is insufficient. The jury should be instructed that they must either unanimously agree that the defendant committed the same act or acts or that the defendant committed all the acts alleged. However, where multiple similar acts are part of one continuous episode, a special unanimity instruction is not required.

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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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