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find waiver in Indiana

11 Indiana opinions name it 2 courts 1994–2025 4 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 (5)

CaseFollowedCited
Averhart v. Stategreen
ind · 1984 · cited in 4 Indiana opinions naming this issue, 1999–2024
2 sentences

1999As the Court of Appeals correctly observed, “[o]nly in cases in which there is such ‘flagrant imposition of the grand jurors’ will or independent judgment’ will the court find a violation of due process.” Wurster , 708 N.E.2d at 592 (quoting Averhart v. State , 470 N.E.2d 666, 679 (Ind. 1984)).

1999As the Court of Appeals correctly observed, “[o]nly in cases in which there is such ‘flagrant imposition of the grand jurors’ will or independent judgment’ will the court find a violation of due process.” Wurster, 708 N.E.2d at 592 (quoting Averhart v. State, 470 N.E.2d 666, 679 (Ind.1984)).

44
In re Saargreen
· 2018 · cited in 3 Indiana opinions naming this issue, 2023–2025
2 sentences

2025In response to our Supreme Court’s holding in Lewis, the General Assembly codified Indiana Code Section 31-32-5-1, which governs the waiver of rights guaranteed to a juvenile, and currently provides, in relevant part: Any rights guaranteed to a child under the Constitution of the United States, the Constitution of the State of Indiana, or any other law may be waived only: ***** (2) by the child’s custodial parent, guardian, custodian, or guardian ad litem if: (A) that person knowingly and voluntarily waives the right; (B) that person has no interest adverse to the child; (C) meaningful consult

2025Moreover, as we previously discussed in T.D., “[b]y permitting a court to find waiver in only these limited circumstances, ‘the [Juvenile Waiver Statute] affords juveniles with greater rights than the Constitution requires.’” T.D., 219 N.E.3d at 725 (quoting R.R. v. State, 106 N.E.3d 1037, 1043 (Ind. 2018)).

33
Gerrick v. Stategreen
ind · 1983 · cited in 2 Indiana opinions naming this issue, 1994–2016
2 sentences

2016Daniel v. State (1991), Ind., 582 N.E.2d 364, 368 ; [Gerrick v. State, 451 N.E.2d 327, 330 (Ind. Court of Appeals of Indiana | Memorandum Decision 90A02-1603-PC-581 | October 21, 2016 Page 12 of 25 1983)].

1994Daniel v. State (1991), Ind., 582 N.E.2d 364, 368 ; Gerrick, 451 N.E.2d at 330 .

12
Vance v. Stategreen
ind · 1994 · cited in 1 Indiana opinions naming this issue, 2010–2010
1 sentence

2010However, our supreme court has held that the lack of such findings does not invalidate the order "if the record contains sufficient facts for the court to find that waiver is appropriate." Vance v. State, 640 N.E.2d 51, 57 (Ind.1994).

11
Trowbridge v. Stategreen
ind · 1999 · cited in 1 Indiana opinions naming this issue, 2005–2005
2 sentences

2005Trowbridge v. State, 717 N.E.2d 138, 149 (Ind.1999).

2005Trowbridge v. State, 717 N.E.2d 138, 149 (Ind.1999).

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 (4)

CaseCitedYears
Daniel v. State green
ind · 1991
2 sentences

2016Daniel v. State (1991), Ind., 582 N.E.2d 364, 368 ; [Gerrick v. State, 451 N.E.2d 327, 330 (Ind. Court of Appeals of Indiana | Memorandum Decision 90A02-1603-PC-581 | October 21, 2016 Page 12 of 25 1983)].

1994Daniel v. State (1991), Ind., 582 N.E.2d 364, 368 ; Gerrick, 451 N.E.2d at 330 .

21994–2016
Wurster v. State green
indctapp · 1999
2 sentences

1999As the Court of Appeals correctly observed, “[o]nly in cases in which there is such ‘flagrant imposition of the grand jurors’ will or independent judgment’ will the court find a violation of due process.” Wurster , 708 N.E.2d at 592 (quoting Averhart v. State , 470 N.E.2d 666, 679 (Ind. 1984)).

1999As the Court of Appeals correctly observed, “[o]nly in cases in which there is such ‘flagrant imposition of the grand jurors’ will or independent judgment’ will the court find a violation of due process.” Wurster, 708 N.E.2d at 592 (quoting Averhart v. State, 470 N.E.2d 666, 679 (Ind.1984)).

21999–1999
DM v. State green
ind · 2011
1 sentence

2025“If the statute is not followed, the State cannot use any statements as evidence.” Id. [31] Our Supreme Court has held that four requirements “must be satisfied before a juvenile’s statements made during a custodial interrogation can be used in the State’s case-in-chief.” D.M., 949 N.E.2d at 333-34 .

12025–2025
B.A. v. State green
ind · 2018
2 sentences

2025In response to our Supreme Court’s holding in Lewis, the General Assembly codified Indiana Code Section 31-32-5-1, which governs the waiver of rights guaranteed to a juvenile, and currently provides, in relevant part: Any rights guaranteed to a child under the Constitution of the United States, the Constitution of the State of Indiana, or any other law may be waived only: ***** (2) by the child’s custodial parent, guardian, custodian, or guardian ad litem if: (A) that person knowingly and voluntarily waives the right; (B) that person has no interest adverse to the child; (C) meaningful consult

2025“If the statute is not followed, the State cannot use any statements as evidence.” Id. [31] Our Supreme Court has held that four requirements “must be satisfied before a juvenile’s statements made during a custodial interrogation can be used in the State’s case-in-chief.” D.M., 949 N.E.2d at 333-34 .

12025–2025

Statutes the citing opinions construe

IN § Ind. Code § 31-32-5-1 (3) IN § Ind. Code § 35-34-1-1 (3) IN § Ind. Code § 35-34-1-7 (3) IN § Ind. Code § 35-34-2-5 (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

CA 15 (1923–2025) OH 13 (1962–2022) PA 12 (1971–2024) LA 11 (1981–2016) IN 11 (1994–2025) FL 9 (1939–2013) CT 9 (1984–2017) NY 8 (1986–2010) AL 8 (1979–2017) IL 8 (1981–2021) TX 7 (1982–2019) KY 6 (1971–2024) NJ 5 (1993–2022) MS 5 (1990–2019) MO 4 (1936–2022) WV 4 (1982–2016) GA 4 (1987–1997) NM 4 (1979–2018) IA 4 (2017–2023) CO 3 (1957–1993) OK 3 (1998–2016) NC 3 (2004–2023) UT 3 (2018–2024) WI 3 (1992–2021) VA 2 (2022–2023) MA 2 (1996–2005) ID 2 (2015–2015) KS 2 (2015–2018) AZ 2 (1976–1983) VT 2 (1922–2018)

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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