sua sponte inquiry (Indiana) · Go Syfert
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sua sponte inquiry in Indiana

6 Indiana opinions name it 1 courts 2002–2023 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 (5)

CaseFollowedCited
Hudson v. Stategreen
indctapp · 1984 · cited in 3 Indiana opinions naming this issue, 2002–2006
2 sentences

2006Hudson v. State, 462 N.E.2d 1077, 1081 (Ind.Ct.App. 1984).

2002“This does not require a sua sponte inquiry; rather the defendant cannot be prevented from explaining.” Hudson v. State, 462 N.E.2d 1077, 1081 (Ind.Ct.App.1984).

33
In Re the Commitment of Golub v. Gilesgreen
indctapp · 2004 · cited in 1 Indiana opinions naming this issue, 2023–2023
1 sentence

2023We therefore turn to the merits of this appeal. 2 C.P. also argues that a history of commitments itself is a collateral consequence that enables appellate review, noting that Indiana Code section 12-26-3-9 expressly restricts the type of commitment a trial court may order based on the respondent’s history of commitments and that our Court has likewise recognized that a “history of mental illness requiring hospitalizations” may be probative of whether a person is “gravely disabled and should be involuntarily committed.” Golub v. Giles, 814 N.E.2d 1034, 1039 (Ind. Ct. App. 2004), trans.

11
Griffin v. Stategreen
ind · 1994 · cited in 1 Indiana opinions naming this issue, 2023–2023
1 sentence

2023In addressing whether it was proper to give the sua sponte instruction, this court applied the Wright test, first finding that, under step one of the test, voluntary manslaughter is an inherently included offense of murder 3 and, under the third step, there was “sufficient evidence of sudden heat” to warrant the giving of the instruction. 4 3 The Washington court cited Griffin v. State, 644 N.E.2d 561, 562 (Ind. 1994), for the proposition that “voluntary manslaughter is simply murder mitigated by sudden heat.” Our Supreme Court later clarified in Watts v. State that, “even though under Indiana

11
Watts v. Stategreen
ind · 2008 · cited in 1 Indiana opinions naming this issue, 2023–2023
1 sentence

2023In addressing whether it was proper to give the sua sponte instruction, this court applied the Wright test, first finding that, under step one of the test, voluntary manslaughter is an inherently included offense of murder 3 and, under the third step, there was “sufficient evidence of sudden heat” to warrant the giving of the instruction. 4 3 The Washington court cited Griffin v. State, 644 N.E.2d 561, 562 (Ind. 1994), for the proposition that “voluntary manslaughter is simply murder mitigated by sudden heat.” Our Supreme Court later clarified in Watts v. State that, “even though under Indiana

11
Holtz v. Stategreen
indctapp · 2006 · cited in 1 Indiana opinions naming this issue, 2018–2018
2 sentences

2018Holtz v. State, 858 N.E.2d 1059, 1063 (Ind. Ct. App. 2006), trans. denied (2007).

2018Holtz v. State , 858 N.E.2d 1059 , 1063 (Ind. Ct. App. 2006), trans. denied (2007).

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 (1)

CaseCitedYears
Ross v. State green
indctapp · 2007
1 sentence

2023In Ross v. State, 877 N.E.2d 829 (Ind. Ct. App. 2008), trans. denied, this court, while addressing the denial of petition for post-conviction relief, evaluated whether the defendant received ineffective assistance of trial counsel for counsel’s failure to object to the trial court’s sua sponte instruction on Class A felony voluntary manslaughter as a lesser included offense of murder.

12023–2023

Where else courts name it

CA 170 (1968–2026) NY 88 (1988–2026) TX 21 (1992–2025) MO 21 (1973–2024) DC 12 (1972–2017) MI 12 (1976–2025) MA 11 (1980–2023) OH 10 (1991–2016) MS 10 (2001–2007) GA 7 (2007–2026) KS 7 (2000–2024) NJ 6 (2006–2020) CO 6 (1996–2025) OK 6 (2002–2024) IN 6 (2002–2023) AZ 6 (1980–2023) PA 5 (1979–2025) NC 4 (1976–2021) IL 4 (1995–2026) RI 4 (2010–2013) HI 3 (2000–2011) TN 3 (2000–2015) NV 2 (1986–2020) ID 2 (2012–2024) WV 2 (1991–2025) AL 2 (2000–2016) OR 2 (1999–2025) WA 2 (2008–2008) CT 2 (1999–2017)

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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