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Indiana Supreme Court: 5 Criminal Case Opinions in December
Posted in Litigation

The Indiana Supreme Court issued five criminal case opinions in December.

In Armfield v. State and Holly v. State, the Indiana Supreme Court “provide[d] the analytical framework” to resolve the issue “of when an officer has reasonable suspicion to initiate a traffic stop after a routine status check of a license plate reveals that the driver’s license of the registered owner of the vehicle is suspended.”

In Armfield, the Court set forth the rule that “an officer has reasonable suspicion to initiate a Terry stop when (1) the officer knows that the registered owner of a vehicle has a suspended license and (2) the officer is unaware of any evidence or circumstances which indicate that the owner is not the driver of the vehicle.”  The Court also explained, “This rule does not require officers to match the physical description of the registered owner from the license plate check to the driver of the vehicle before initiating a Terry stop.”  In both Armfield and Holly, the Court concluded that the officer making the stop had a reasonable suspicion to initiate a stop based on computer records indicating that the vehicle’s registered owner had a suspended driver’s license.

The two cases produced different outcomes, however.  In Armfield, the officer confirmed that the driver was the owner whose license was suspended.  In Holly, though, the officer knew upon approaching the driver that the driver (a male) was not the registered owner (a female).  Nevertheless, the officer asked the driver to produce his license.  Noting that “[r]easonable suspicion to pull a car over does not confer unconditional authority to request the driver’s license and registration,” the Court explained that nothing in the record justified any further inquiry beyond the Terry stop.  Thus, the Court concluded, evidence of drugs in the car that was discovered during a subsequent search was improperly obtained and inadmissible.

In Cooper v. State, the Court explained that the proper vehicle to challenge a trial court’s revocation of probation is through an immediate appeal of the order.  In Cooper, the trial court revoked probation without conducting a hearing – a circumstance the Court explained would have led to a reversal had Cooper timely appealed the order.  However, Cooper waited for additional facts to develop, then moved the trial court for reconsideration.  The trial court denied the motion and – on appeal from the denial of that motion – the Court concluded that the trial court did not abuse its discretion.

In Lafayette v. State, the Indiana Supreme Court reversed a rape conviction based on the State’s use of evidence of the defendant’s conviction for attempted rape ten years earlier.  The Court concluded that the evidence should have been excluded under Indiana Rule of Evidence 404(b), over the State’s contention that it was admissible to prove the defendant’s intent to commit the present rape.  The trial court had agreed that the defendant’s “intent,” for 404(b) purposes, was put at issue when the defendant challenged the alleged victim’s credibility.  The Court disagreed, holding that a “defendant’s use of the defense of consent in a rape prosecution is not, standing alone, enough to trigger the availability of the intent exception.”

In Wilkes v. State, the Indiana Supreme Court affirmed a death sentence on direct appeal, over challenges to the admissibility of confessions given by the defendant, evidence of other crimes used to prove motive for the murders, and the propriety of the sentence.

 

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