habitual offender hearing (Indiana) · Go Syfert
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habitual offender hearing in Indiana

13 Indiana opinions name it 2 courts 1982–2023 1 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 (4)

CaseFollowedCited
Sample v. Stategreen
ind · 2010 · cited in 2 Indiana opinions naming this issue, 2013–2023
2 sentences

2023It was unnecessary to constitutionalize the jury’s right to determine the law in a habitual offender hearing, the Court reasoned, given that the “law and facts” statute also guaranteed it. 895 N.E.2d at 1185 . 8 Seay was correct in its holding and its original constitutional basis. 9 The legislature has provided for a jury trial in habitual offender status 8 The revised, non-constitutional basis for the jury’s role went unrecognized in Sample v. State, which reverted to reliance on “the jury’s Article I, Section 19 authority.” 932 N.E.2d 1230 , 1233 (Ind. 2010). 9This determination that Articl

2013See Sample v. State, 932 N.E.2d 1230 (Ind. 2010).

12
Girl Scouts of Southern Illinois v. Vincennes Indiana Girls, Inc.green
ind · 2013 · cited in 1 Indiana opinions naming this issue, 2023–2023
1 sentence

2023This Court will “generally avoid addressing constitutional questions if a case can be resolved on other grounds.” Girl Scouts of S. Illinois v. Vincennes Indiana Girls, Inc., 988 N.E.2d 250, 254 (Ind. 2013) (citations omitted).

11
Canaan v. Stategreen
ind · 1997 · cited in 1 Indiana opinions naming this issue, 2013–2013
1 sentence

2013See, e.g., Canaan v. State, 683 N.E.2d 227, 235 (Ind. 1997) (“An available grounds for relief not raised at trial or on direct appeal is not available as a grounds for collateral attack.”).

11
United States v. Tuckergreen
scotus · 1972 · cited in 1 Indiana opinions naming this issue, 1982–1982
2 sentences

1982Compare United States v. Tucker (1972), 404 U.S. 443 , 92 S.Ct. 589 , 30 L.Ed.2d 592 .

1982Compare United States v. Tucker (1972), 404 U.S. 443 , 92 S.Ct. 589 , 30 L.Ed.2d 592 .

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 (11)

CaseCitedYears
Snyder v. State green
ind · 1996
2 sentences

2012Id.

1999In contrast, Snyder, 668 N.E.2d 1214 involved a plea agreement regarding the underlying offenses, with a bench trial on the habitual offender claim.

21999–2012
Williams v. State neutral
ind · 1982
2 sentences

1989Williams v. State (1982), Ind., 431 N.E.2d 793 .

1985Williams v. State (1982), Ind., 431 N.E.2d 793 .

21985–1989
State v. Hollars green
ind · 2008
1 sentence

2023It was unnecessary to constitutionalize the jury’s right to determine the law in a habitual offender hearing, the Court reasoned, given that the “law and facts” statute also guaranteed it. 895 N.E.2d at 1185 . 8 Seay was correct in its holding and its original constitutional basis. 9 The legislature has provided for a jury trial in habitual offender status 8 The revised, non-constitutional basis for the jury’s role went unrecognized in Sample v. State, which reverted to reliance on “the jury’s Article I, Section 19 authority.” 932 N.E.2d 1230 , 1233 (Ind. 2010). 9This determination that Articl

12023–2023
Maffett v. State green
indctapp · 2002
1 sentence

2003Id. 8 .

12003–2003
Boykin v. State green
indctapp · 1998
1 sentence

1999We note that in Boykin v. State, 702 N.E.2d 1105 (Ind.Ct.App.1998) a panel of this court determined that when a habitual offender conviction was vacated, the conviction of the underlying offense must also be vacated.

11999–1999
Snyder v. State green
indctapp · 1995
2 sentences

1997Snyder, 654 N.E.2d at 19 .

1997Snyder, 654 N.E.2d at 19 .

11997–1997
Lawrence v. State green
ind · 1972
2 sentences

1985Defendant relies on Lawrence v. State (1972), 259 Ind. 306 , 286 N.E.2d 830 , wherein we held that the habitual offender hearing must be bifurcated from the trial on the underlying felony, because disclosure of a defendant's prior convictions during a trial on both the underlying offense and habitual offender count would prejudice the jury to a defendant's detriment.

1985Defendant relies on Lawrence v. State (1972), 259 Ind. 306 , 286 N.E.2d 830 , wherein we held that the habitual offender hearing must be bifurcated from the trial on the underlying felony, because disclosure of a defendant's prior convictions during a trial on both the underlying offense and habitual offender count would prejudice the jury to a defendant's detriment.

11985–1985
Barnett v. State green
ind · 1981
1 sentence

1984McConnell v. State, (1982) Ind., 436 N.E.2d 1097, 1102 ; Barnett v. State, (1981) Ind., 429 N.E.2d 625, 626 .

11984–1984
McConnell v. State green
ind · 1982
1 sentence

1984McConnell v. State, (1982) Ind., 436 N.E.2d 1097, 1102 ; Barnett v. State, (1981) Ind., 429 N.E.2d 625, 626 .

11984–1984
Haynes v. State green
indctapp · 1982
1 sentence

1983We are cognizant that our -courts apparently have recognized the right of a person charged with being an habitual offender to challenge the validity of the underlying felony convictions on constitutional grounds, Hall v. State, (1980) Ind., 405 N.E.2d 530 ; Haynes v. State, (1982) Ind.App., 436 N.E.2d 874 , although some question exists as to the precise method for doing so.

11983–1983
Hall v. State green
ind · 1980
1 sentence

1983We are cognizant that our -courts apparently have recognized the right of a person charged with being an habitual offender to challenge the validity of the underlying felony convictions on constitutional grounds, Hall v. State, (1980) Ind., 405 N.E.2d 530 ; Haynes v. State, (1982) Ind.App., 436 N.E.2d 874 , although some question exists as to the precise method for doing so.

11983–1983

Statutes the citing opinions construe

IN § Ind. Code § 35-50-2-8 (8)

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

LA 187 (1978–2026) IN 13 (1982–2023) MS 12 (1988–2013) VA 8 (1981–2018) FL 7 (1991–2004) NM 5 (1996–2025) TN 3 (1993–2012) ND 3 (2019–2019) AL 2 (1981–1985) MI 2 (1980–1981)

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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