Richardson test (Indiana) · Go Syfert
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Richardson test in Indiana

22 Indiana opinions name it 3 courts 2000–2024 2 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
Guyton v. Stategreen
ind · 2002 · cited in 2 Indiana opinions naming this issue, 2002–2008
2 sentences

2008As the Supreme Court recognized in Guyton v. State, 771 N.E.2d 1141, 1143 (Ind.2002), the two-part Richardson test is not the exclusive measure of double jeopardy violations.

2008As the Supreme Court recognized in Guyton v. State, 771 N.E.2d 1141, 1143 (Ind.2002), the two-part Richardson test is not the exclusive measure of double jeopardy violations.

22
Richardson v. Stategreen
ind · 1999 · cited in 6 Indiana opinions naming this issue, 2002–2019
2 sentences

2019See Thy Ho v. State, 725 N.E.2d 988, 992 (Ind. Ct. App. 2000) (charges of armed robbery and theft Court of Appeals of Indiana | Memorandum Decision 18A-CR-2624 | May 23, 2019 Page 15 of 21 did not violate statutory elements test; the offenses as charged involved different victims and different types of property). [40] When the statutory elements test does not disclose a double jeopardy violation, we turn to the second part of the Richardson analysis, the actual elements test. 717 N.E.2d at 52 .

2019See Thy Ho v. State, 725 N.E.2d 988, 992 (Ind. Ct. App. 2000) (charges of armed robbery and theft Court of Appeals of Indiana | Memorandum Decision 18A-CR-2624 | May 23, 2019 Page 15 of 21 did not violate statutory elements test; the offenses as charged involved different victims and different types of property). [40] When the statutory elements test does not disclose a double jeopardy violation, we turn to the second part of the Richardson analysis, the actual elements test. 717 N.E.2d at 52 .

16
Spivey v. Stategreen
ind · 2002 · cited in 2 Indiana opinions naming this issue, 2002–2002
2 sentences

2002Accordingly, the dual convictions do not run afoul of the Richardson test as recently considered in Spivey v. State, 761 N.E.2d 831 (Ind.2002). 4 In all other respects I fully concur. .

2002Accordingly, the dual convictions do not run afoul of the Richardson test as recently considered in Spivey v. State, 761 N.E.2d 831 (Ind.2002). 4 In all other respects I fully concur. .

12
Billy Deon Blackmon v. State of Indianagreen
indctapp · 2015 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019See Cartwright, 962 N.E.2d at 1222 (providing that neither state nor federal law require a trial court to make explicit findings when deciding whether the State offered a race-neutral reason for striking a potential juror); Blackmon, 47 N.E.3d at 1234 (indicating that the trial court is not required to make explicit findings every time the prosecution justifies a peremptory strike based on a juror’s demeanor).

11
Thy Ho v. Stategreen
indctapp · 2000 · cited in 1 Indiana opinions naming this issue, 2019–2019
2 sentences

2019See Thy Ho v. State, 725 N.E.2d 988, 992 (Ind. Ct. App. 2000) (charges of armed robbery and theft Court of Appeals of Indiana | Memorandum Decision 18A-CR-2624 | May 23, 2019 Page 15 of 21 did not violate statutory elements test; the offenses as charged involved different victims and different types of property). [40] When the statutory elements test does not disclose a double jeopardy violation, we turn to the second part of the Richardson analysis, the actual elements test. 717 N.E.2d at 52 .

2019See Thy Ho v. State, 725 N.E.2d 988, 992 (Ind. Ct. App. 2000) (charges of armed robbery and theft Court of Appeals of Indiana | Memorandum Decision 18A-CR-2624 | May 23, 2019 Page 15 of 21 did not violate statutory elements test; the offenses as charged involved different victims and different types of property). [40] When the statutory elements test does not disclose a double jeopardy violation, we turn to the second part of the Richardson analysis, the actual elements test. 717 N.E.2d at 52 .

11
Cartwright v. Stategreen
ind · 2012 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019See Cartwright, 962 N.E.2d at 1222 (providing that neither state nor federal law require a trial court to make explicit findings when deciding whether the State offered a race-neutral reason for striking a potential juror); Blackmon, 47 N.E.3d at 1234 (indicating that the trial court is not required to make explicit findings every time the prosecution justifies a peremptory strike based on a juror’s demeanor).

11
Richardson's RV Inc. v. Indiana Department of State Revenuegreen
indtc · 2017 · cited in 1 Indiana opinions naming this issue, 2017–2017
2 sentences

2017See generally Richardson’s RV Inc. v. Ind. Dep’t of State Revenue, No. 49T10-1504-TA-00016, 80 N.E.3d 293 , 2017 WL 3300828 , Slip. op., (Ind. Tax Ct. August 1, 2017).

2017See generally Richardson’s RV Inc. v. Ind. Dep’t of State Revenue, No. 49T10-1504-TA-00016, 80 N.E.3d 293 , 2017 WL 3300828 , Slip. op., (Ind. Tax Ct. August 1, 2017).

11
Bruce v. Stategreen
indctapp · 2001 · cited in 1 Indiana opinions naming this issue, 2016–2016
1 sentence

2016We must determine whether Gonzalez’s conviction of Class B felony unlawful possession of a firearm by a serious violent offender required the trial court to reduce Gonzalez’s convictions of robbery and criminal confinement from Class B to Class C felonies. [12] Under the “actual evidence” test, we must examine the evidence presented at trial to determine “whether each challenged offense was established by separate and distinct facts.” Bruce v. State, 749 N.E.2d 587, 590 (Ind. Ct. App. 2001) (quoting Richardson, 717 N.E.2d at 53 ), trans. denied.

11
Bald v. Stategreen
ind · 2002 · cited in 1 Indiana opinions naming this issue, 2016–2016
2 sentences

2016Id. at 53 . [41] Our supreme court clarified the Richardson test in Bald v. State, holding that no violation of the actual evidence test occurs as long as “each conviction [contains] proof of at least one unique evidentiary fact.” 766 N.E.2d 1170, 1172 (Ind. 2002).

2016Id. at 53 . [41] Our supreme court clarified the Richardson test in Bald v. State, holding that no violation of the actual evidence test occurs as long as “each conviction [contains] proof of at least one unique evidentiary fact.” 766 N.E.2d 1170, 1172 (Ind. 2002).

11
Taylor v. Finnangreen
indctapp · 2011 · cited in 1 Indiana opinions naming this issue, 2014–2014
1 sentence

2014See Taylor, 955 N.E.2d at 789 (writ of habeas corpus based on a lawyer not being licensed in Indiana was properly reclassified as a petition for post-conviction relief because the judgment was not void on its face).

11
KOA Properties, LLC v. Laura Matheisongreen
indctapp · 2013 · cited in 1 Indiana opinions naming this issue, 2014–2014
1 sentence

2014Richardson’s motion to correct error challenged the denial of her “Emergency Motion to Continue or in the Alternative Motion to Set Aside Judgment.” (App. 22.) Indiana Small Claims Rule 10(B) provides in relevant part: “If the defendant fails to appear at the time and place specified in the notice of claim, or for any continuance thereof, the court may enter a default judgment against him.” One who seeks to set aside a default judgment is subject to section 10(C), which provides in part: “Upon good cause shown the court may, within one year after entering default judgment, vacate such judgment

11
Jones v. Stategreen
indctapp · 2004 · cited in 1 Indiana opinions naming this issue, 2013–2013
2 sentences

2013Id. at 824.

2013Id. at 824.

11
Goldsberry v. Stategreen
indctapp · 2005 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See Goldberry, 821 N.E.2d at 459 . 7 35-48-4-6 is a lesser included offense of dealing in cocaine.2 Harrison v. State, 901 N.E.2d 635, 643 (Ind. Ct. App. 2009), trans. denied.

2012See Goldberry, 821 N.E.2d at 459 . 7 35-48-4-6 is a lesser included offense of dealing in cocaine.2 Harrison v. State, 901 N.E.2d 635, 643 (Ind. Ct. App. 2009), trans. denied.

11
Harrison v. Stategreen
indctapp · 2009 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See Goldberry, 821 N.E.2d at 459 . 7 35-48-4-6 is a lesser included offense of dealing in cocaine.2 Harrison v. State, 901 N.E.2d 635, 643 (Ind. Ct. App. 2009), trans. denied.

2012See Goldberry, 821 N.E.2d at 459 . 7 35-48-4-6 is a lesser included offense of dealing in cocaine.2 Harrison v. State, 901 N.E.2d 635, 643 (Ind. Ct. App. 2009), trans. denied.

11
Muehler v. Menagreen
scotus · 2005 · cited in 1 Indiana opinions naming this issue, 2009–2009
2 sentences

2009See Muchler v. Mena, 544 U.S. 93, 101 , 125 S.Ct. 1465 , 161 LEd.2d 299 (2005).

2009See Muchler v. Mena, 544 U.S. 93, 101 , 125 S.Ct. 1465 , 161 LEd.2d 299 (2005).

11
Sensback v. Stategreen
ind · 1999 · cited in 1 Indiana opinions naming this issue, 2009–2009
1 sentence

2009See Sensback v. State, 720 N.E.2d 1160, 1165 (Ind.1999).

11
Kingery v. Stategreen
ind · 1995 · cited in 1 Indiana opinions naming this issue, 2002–2002
1 sentence

2002Quoting Pierce , and relying upon the pre-Richardson analysis in Kingery v. State, 659 N.E.2d 490, 495-96 (Ind.1995), the court in Gross v. State, 769 N.E.2d 1136, 1139 (Ind.2002), determined that a murder conviction and a robbery conviction enhanced to a class A felony based upon the same acts subsumed in the murder could not both stand.

11
Gross v. Stategreen
ind · 2002 · cited in 1 Indiana opinions naming this issue, 2002–2002
1 sentence

2002Quoting Pierce , and relying upon the pre-Richardson analysis in Kingery v. State, 659 N.E.2d 490, 495-96 (Ind.1995), the court in Gross v. State, 769 N.E.2d 1136, 1139 (Ind.2002), determined that a murder conviction and a robbery conviction enhanced to a class A felony based upon the same acts subsumed in the murder could not both stand.

11
Williams v. Stategreen
ind · 1996 · cited in 1 Indiana opinions naming this issue, 2000–2000
1 sentence

2000Williams v. State, 669 N.E.2d 1372, 1375-76 (Ind.1996), cert. denied, 520 U.S. 1232 , 117 S.Ct. 1828 , 137 L.Ed.2d 1034 (1997).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Juan M. Garrett v. State of Indiana green
ind · 2013
2 sentences

2024The court then stated that, “[b]ecause Wadle’s case presents no question of procedural double jeopardy, we expressly reserve any conclusion on whether to overrule Richardson in that context.” Id. 4 Our supreme court first utilized the Richardson test to address a claim of procedural double jeopardy in Garrett v. State, 992 N.E.2d 710 (Ind. 2013).

2024The court then stated that, “[b]ecause Wadle’s case presents no question of procedural double jeopardy, we expressly reserve any conclusion on whether to overrule Richardson in that context.” Id. 4 Our supreme court first utilized the Richardson test to address a claim of procedural double jeopardy in Garrett v. State, 992 N.E.2d 710 (Ind. 2013).

12024–2024
State v. Richardson green
ind · 2010
1 sentence

2023Id.

12023–2023
Drane v. State green
ind · 2007
1 sentence

2019Drane v. State, 867 N.E.2d 144 , 146–47 (Ind. 2007) (citations, emphasis, and quotations omitted). [25] Initially, we note that Richardson’s claim regarding the sufficiency of the evidence was based entirely on his claim that the trial court abused its discretion in admitting Exhibits 3, 6, and 7.

12019–2019
State v. Richardson neutral
indctapp · 2009
1 sentence

2010State v. Richardson, 906 N.E.2d 263 (Ind.Ct.App.2009).

12010–2010
Alexander v. State green
indctapp · 2002
2 sentences

2002The Richardson/Spivey analysis is considered in Alexander v. State, 768 N.E.2d 971 (Ind.Ct.App.2002) also decided this date.

2002The Richardson/Spivey analysis is considered in Alexander v. State, 768 N.E.2d 971 (Ind.Ct.App.2002) also decided this date.

12002–2002
Taylor v. State green
ind · 1999
2 sentences

2000Atchley acknowledges that the Richardson analysis may not be applied retroactively in a post-conviction proceeding, and therefore that he “cannot rely on the actual evidence test announced in Richardson to argue that appellate counsel was ineffective for not raising a double jeopardy argument on appeal.” Appellant’s Brief at 17 (citing Taylor v. State, 717 N.E.2d 90 ).

2000Atchley acknowledges that the Richardson analysis may not be applied retroactively in a post-conviction proceeding, and therefore that he “cannot rely on the actual evidence test announced in Richardson to argue that appellate counsel was ineffective for not raising a double jeopardy argument on appeal.” Appellant’s Brief at 17 (citing Taylor v. State, 717 N.E.2d 90 ).

12000–2000
Mitchell v. Albuquerque Board of Education green
scotus · 1997
1 sentence

2000Williams v. State, 669 N.E.2d 1372, 1375-76 (Ind.1996), cert. denied, 520 U.S. 1232 , 117 S.Ct. 1828 , 137 L.Ed.2d 1034 (1997).

12000–2000
White v. O'Connor green
scotus · 1997
1 sentence

2000Williams v. State, 669 N.E.2d 1372, 1375-76 (Ind.1996), cert. denied, 520 U.S. 1232 , 117 S.Ct. 1828 , 137 L.Ed.2d 1034 (1997).

12000–2000
Dye v. Michigan green
scotus · 1997
1 sentence

2000Williams v. State, 669 N.E.2d 1372, 1375-76 (Ind.1996), cert. denied, 520 U.S. 1232 , 117 S.Ct. 1828 , 137 L.Ed.2d 1034 (1997).

12000–2000

Statutes the citing opinions construe

IN § Ind. Code § 35-42-1-1 (4) IN § Ind. Code § 35-42-2-1 (4) IN § Ind. Code § 35-47-2-1 (4) IN § Ind. Code § 35-41-5-2 (3) IN § Ind. Code § 35-42-3-3 (3) IN § Ind. Code § 35-48-4-1 (3) IN § Ind. Code § 35-50-1-2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

FL 369 (1979–2025) IN 22 (2000–2024) NJ 22 (2011–2026) TX 19 (1966–2024) GA 14 (1987–2026) CA 10 (2001–2016) MS 9 (1997–2022) OH 8 (2004–2017) IL 8 (1973–2023) PA 7 (1976–2025) NC 7 (1976–2020) WA 5 (2011–2019) VA 4 (1995–2025) AR 4 (1986–2014) IA 4 (1973–2019) MN 4 (1994–2014) AZ 4 (1984–2023) NE 3 (2017–2023) AL 3 (2004–2011) TN 3 (2010–2010) VI 3 (2013–2025) HI 3 (2005–2015) NV 3 (2006–2018) LA 3 (2000–2016) MD 3 (1919–2022) KY 2 (1972–2020) NM 2 (1956–1998) KS 2 (1995–1999) NY 2 (2008–2020) WY 2 (1990–1993) SD 2 (1995–2009) MT 2 (2006–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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