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7 Indiana opinions name it 1 courts 2000–2017 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.
| Case | Followed | Cited |
|---|---|---|
Umfleet v. Stategreen1 sentence2010In regard to this concealment exception to the statute of limitation, we have explained that the phrase concealing evidence of the offense "must be held to mean concealment of the fact that a crime has been committed, unconnected with the fact that the accused was the perpetrator" and that "the concealment of the fact of the crime must be the result of some positive act done by the accused, and calculated to prevent discovery of the fact of the offense of which he stands charged." State v. Chrzan, 693 N.E.2d 566, 567 (Ind.Ct.App.1998) (quoting State v. Holmes, 181 Ind.App. 634, 637 , 393 N.E.2 | 1 | 1 |
State v. Holmesgreen2 sentences2010In regard to this concealment exception to the statute of limitation, we have explained that the phrase concealing evidence of the offense "must be held to mean concealment of the fact that a crime has been committed, unconnected with the fact that the accused was the perpetrator" and that "the concealment of the fact of the crime must be the result of some positive act done by the accused, and calculated to prevent discovery of the fact of the offense of which he stands charged." State v. Chrzan, 693 N.E.2d 566, 567 (Ind.Ct.App.1998) (quoting State v. Holmes, 181 Ind.App. 634, 637 , 393 N.E.2 2010In regard to this concealment exception to the statute of limitation, we have explained that the phrase concealing evidence of the offense "must be held to mean concealment of the fact that a crime has been committed, unconnected with the fact that the accused was the perpetrator" and that "the concealment of the fact of the crime must be the result of some positive act done by the accused, and calculated to prevent discovery of the fact of the offense of which he stands charged." State v. Chrzan, 693 N.E.2d 566, 567 (Ind.Ct.App.1998) (quoting State v. Holmes, 181 Ind.App. 634, 637 , 393 N.E.2 | 1 | 1 |
State v. Chrzangreen1 sentence2010In regard to this concealment exception to the statute of limitation, we have explained that the phrase concealing evidence of the offense "must be held to mean concealment of the fact that a crime has been committed, unconnected with the fact that the accused was the perpetrator" and that "the concealment of the fact of the crime must be the result of some positive act done by the accused, and calculated to prevent discovery of the fact of the offense of which he stands charged." State v. Chrzan, 693 N.E.2d 566, 567 (Ind.Ct.App.1998) (quoting State v. Holmes, 181 Ind.App. 634, 637 , 393 N.E.2 | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hinds v. McNair
green
2 sentences2010Id. 2010Id. | 2 | 2010–2010 |
Malachowski v. Bank One, Indianapolis
green
2 sentences2017“A mere failure to disclose, when there is a duty to disclose, may be sufficient to toll the statute.” Id. 2017“However, where the parties are in a fiduciary relationship, such as trustee/beneficiary, the concealment of the claim need not be active.” Id. | 1 | 2017–2017 |
Kifer v. State
green
2 sentences2012However, we agree with the holding in Kifer, 740 N.E.2d at 588-89 , that interpreting "evidence of the offense” to include any evidence, including evidence of guilt, would allow the exception to swallow the rule, tolling the statute of limitations in "nearly all crimes in which a defendant attempts to avoid apprehension.” Id. at 589 . 2012However, we agree with the holding in Kifer, 740 N.E.2d at 588-89 , that interpreting "evidence of the offense” to include any evidence, including evidence of guilt, would allow the exception to swallow the rule, tolling the statute of limitations in "nearly all crimes in which a defendant attempts to avoid apprehension.” Id. at 589 . | 1 | 2012–2012 |
Reeves v. State
green
2 sentences2012On this issue, we again agree with the trial court. “ ‘Concealment is a fact-intensive issue.’ ” Appellant’s App. p. 7 (quoting Reeves, 938 N.E.2d at 17 ). 2012On this issue, we again agree with the trial court. “‘Concealment is a fact-intensive issue.’” Appellant’s App. p. 7 (quoting Reeves, 938 N.E.2d at 17 ). | 1 | 2012–2012 |
Sloan v. State
green
1 sentence2012We recognize that our Supreme Court has noted that the "evidence of the offense” language of the concealment exception articulated at Indiana Code section 35 — 41—4—2(h)(2) may apply to “concealment of any evidence, including evidence of guilt, and thus would toll the statute of limitations in any crime in which a defendant tries to avoid apprehension.” Sloan v. State, 947 N.E.2d 917 , 922 n. 8 (Ind.2011). | 1 | 2012–2012 |
Paople v. James
green
1 sentence2000Id. | 1 | 2000–2000 |
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.
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.