Change in visitation to seven nights every two weeks was a de facto change of custody subject to the statutes on custody modification. When considering changing a decree for joint legal custody, the court must consider the joint legal custody factors in IC 31-17-2-15 in addition to the standard factors in IC 31-17-2-8.

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When a person convicted of nonsupport of a dependent must pay support as a condition of probation, he has the burden to prove he was unable to pay at a revocation for having failed to make the support payments.

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If a trial court finds that an attorney or party caused a mistrial by egregiously violating an order in limine, the trial court has the inherent power to sanction him or her.

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Testifying defendant may be impeached with his failure to explain his innocence to the police after he is charged but prior to his receiving Miranda warnings, under the Miranda-based Doyle v. Ohio decisions; Indiana’s law does not offer more protection than the federal Doyle cases.

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Officer reasonably concluded that car approached by armed robbery suspect might have been suspect’s car and exigent circumstances justified officer’s opening vehicle door wider to check for accomplices inside.

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