Published by the Indiana Judicial Center
There is no brightline rule that when an inmate is questioned in prison about events in the outside world there is custody for Miranda purposes.
Declines to adopt a due process judicial reliability screening procedure for eyewitness identification evidence.
The “Confrontation Clause [does not] permit the prosecution to introduce a forensic laboratory report containing a testimonial certification—made for the purpose of proving a particular fact—through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. We hold that surrogate testimony of that order does not meet the constitutional requirement. The accused’s right is to be confronted with the analyst who made the certification, unless that analyst is unavailable at trial, and the accused had an opportunity, pretrial, to cross-examine that particular scientist.”
Exigent circumstances exception permitting warrantless search of a home when police reasonably believe criminal evidence is being destroyed within applies even though the police’s lawful knock and announce at the house door is what prompts the inhabitants to destroy the evidence.
Statement of mortally wounded victim to police was not “testimonial” under Crawford Confrontation Clause holding because circumstances indicated “primary purpose” of the police questions eliciting statement was to “meet an ongoing emergency.”
Jane Seigel, Executive Director
Michael J. McMahon, Director of Research
Amanda Wishin, Staff Attorney
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Case Clips are selected decisions of the Indiana appellate courts abstracted for judges by the Indiana Judicial Center. The full text of Indiana opinions may be retrieved from the Indiana Judicial System website at courts.IN.gov/opinions.
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