two aggravating factors (Indiana) · Go Syfert
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two aggravating factors in Indiana

9 Indiana opinions name it 2 courts 1997–2019 0 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 (8)

CaseFollowedCited
Ridenour v. Stategreen
indctapp · 1994 · cited in 2 Indiana opinions naming this issue, 1997–1998
2 sentences

1998With respect to the other two aggravating factors identified, the trial court's statement was a "generalized statutory recitation." See Ridenour v. State , 639 N.E.2d 288, 296 (Ind. Ct. App. 1994).

1997With respect to the other two aggravating factors identified, the trial court’s statement was a “generalized statutory recitation.” See Ridenour v. State, 639 N.E.2d 288, 296 (Ind.CtApp.1994).

22
Mathews v. Stategreen
ind · 2006 · cited in 1 Indiana opinions naming this issue, 2019–2019
1 sentence

2019See id. (concluding that although “depreciation of the seriousness of the crime should not be relied upon as a factor to order sentences to be served consecutively,” the other two aggravating factors supported consecutive sentences). 2.4 – Gorbonosenko waived his argument that the trial court erred by sentencing him based on speculative facts not in evidence. [32] Last, Gorbonosenko asserts that in imposing sentence, the trial court relied on speculative facts not in evidence.

11
Jakob Robinson v. State of Indianagreen
indctapp · 2016 · cited in 1 Indiana opinions naming this issue, 2017–2017
1 sentence

2017Robinson v. State, 61 N.E.3d 1226, 1228 (Ind. Ct. App. 2016). [26] Here, again, the trial court identified the following two aggravating factors: the emotional harm suffered by the victims and Coop’s abuse of his position of trust over the victims.

11
Pinkston v. Stategreen
indctapp · 2005 · cited in 1 Indiana opinions naming this issue, 2006–2006
1 sentence

2006See Pinkston v. State, 836 N.E.2d 453, 463 (Ind.Ct.App.2005), trans. denied.

11
Higginbotham v. Stategreen
indctapp · 2005 · cited in 1 Indiana opinions naming this issue, 2006–2006
1 sentence

2006A `fixed' plea specifies the exact number of years to be imposed." Nguyen, 837 N.E.2d at 158 n. 14. [7] The State's citation to Higginbotham v. State, 826 N.E.2d 5, 6 (Ind.Ct.App.2005), is unpersuasive given that the case involved a fixed plea. [8] Again, we note that the State did not directly respond to Boyle's challenge to the two aggravating factors. [9] Although often stated, it bears repeating that a potential Blakely problem only arises when aggravating circumstances are used to enhance a sentence beyond the presumptive term.

11
Smylie v. Stategreen
ind · 2005 · cited in 1 Indiana opinions naming this issue, 2006–2006
1 sentence

2006"When sentencing a defendant on multiple counts, an Indiana trial judge may impose a consecutive sentence if he or she finds at least one aggravator." Smylie v. State, 823 N.E.2d 679, 686 (Ind.2005), cert. denied, -- U.S. --, 126 S.Ct. 545 , 163 L.Ed.2d 459 (2005).

11
Ector v. Stategreen
ind · 1994 · cited in 1 Indiana opinions naming this issue, 1998–1998
2 sentences

1998See Ector v. State, 639 N.E.2d 1014, 1016 (Ind.1994).

1998See Ector v. State, 639 N.E.2d 1014, 1016 (Ind.1994).

11
State v. Olivergreen
nc · 1981 · cited in 1 Indiana opinions naming this issue, 1997–1997
2 sentences

1997State v. Oliver, 302 N.C. 28 , 274 S.E.2d 183, 204 (1981).

1997State v. Oliver, 302 N.C. 28 , 274 S.E.2d 183, 204 (1981).

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 (5)

CaseCitedYears
Jones v. State green
ind · 1996
2 sentences

1998"A mere recitation of statutory language in a statement disclosing factors the trial court considered to justify enhancement of presumptive sentence is insufficient to support an enhanced sentence." Jones , 675 N.E.2d at 1087 .

1997“A mere recitation of statutory language in a statement disclosing factors the trial court considered to justify enhancement of presumptive sentence is insufficient to support an enhanced sentence.” Jones, 675 N.E.2d at 1087 .

21997–1998
Rogers v. State neutral
indctapp · 2007
1 sentence

2007Rogers v. State, 860 N.E.2d 929 (Ind.Ct.App.2007) (unpublished).

12007–2007
Nguyen v. State green
indctapp · 2005
1 sentence

2006A `fixed' plea specifies the exact number of years to be imposed." Nguyen, 837 N.E.2d at 158 n. 14. [7] The State's citation to Higginbotham v. State, 826 N.E.2d 5, 6 (Ind.Ct.App.2005), is unpersuasive given that the case involved a fixed plea. [8] Again, we note that the State did not directly respond to Boyle's challenge to the two aggravating factors. [9] Although often stated, it bears repeating that a potential Blakely problem only arises when aggravating circumstances are used to enhance a sentence beyond the presumptive term.

12006–2006
Huckaby v. New York State Division of Tax Appeals green
scotus · 2005
1 sentence

2006"When sentencing a defendant on multiple counts, an Indiana trial judge may impose a consecutive sentence if he or she finds at least one aggravator." Smylie v. State, 823 N.E.2d 679, 686 (Ind.2005), cert. denied, -- U.S. --, 126 S.Ct. 545 , 163 L.Ed.2d 459 (2005).

12006–2006
Hendricks v. Mutual Indemnity (Bermuda), Ltd. green
scotus · 2005
1 sentence

2006"When sentencing a defendant on multiple counts, an Indiana trial judge may impose a consecutive sentence if he or she finds at least one aggravator." Smylie v. State, 823 N.E.2d 679, 686 (Ind.2005), cert. denied, -- U.S. --, 126 S.Ct. 545 , 163 L.Ed.2d 459 (2005).

12006–2006

Statutes the citing opinions construe

IN § Ind. Code § 35-42-1-1 (4) IN § Ind. Code § 35-38-1-7 (3) IN § Ind. Code § 35-38-1-7.1 (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 23 (1982–2023) IN 9 (1997–2019) NC 9 (1983–2021) AZ 8 (2001–2013) NJ 7 (1991–2009) IL 7 (1987–2023) WA 6 (2006–2016) MS 5 (1996–2007) VA 5 (2000–2010) OR 3 (1993–2007) UT 3 (2012–2019) CA 2 (2015–2025) TX 2 (2000–2000) KS 2 (1998–2005)

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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