clarified test in Indiana

2015The Court later clarified this test to mean that the nonresident defendant must engage in “some act by which [he] purposefully avails [himself] of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” Hanson v. Denckla, 357 U.S. 235, 253 , 78 S. Ct. 1228 , 2 L.Ed.2d 1283 (1958).

2015The Court later clarified this test to mean that the nonresident defendant must engage in “some act by which [he] purposefully avails [himself] of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” Hanson v. Denckla, 357 U.S. 235, 253 , 78 S. Ct. 1228 , 2 L.Ed.2d 1283 (1958).

2017Court of Appeals of Indiana | Memorandum Decision 49A02-1609-CR-2079 | August 30, 2017 Page 10 of 17 The search incident to arrest trilogy concludes with [Arizona v. Gant, 556 U.S. 332 , 129 S. Ct. 1710 (2009)], which analyzed searches of an arrestee’s vehicle.

2017Court of Appeals of Indiana | Memorandum Decision 49A02-1609-CR-2079 | August 30, 2017 Page 10 of 17 The search incident to arrest trilogy concludes with [Arizona v. Gant, 556 U.S. 332 , 129 S. Ct. 1710 (2009)], which analyzed searches of an arrestee’s vehicle.

2017A few years later, the Court clarified that this exception was limited to “personal property . . . immediately associated with the person of the arrestee.” United States v. Chadwick, 433 U.S. 1, 15 , 97 S. Ct. 2476 , 53 L.Ed.2d 538 (1977) (200-pound, locked footlocker could not be searched incident to arrest), abrogated on other grounds by California v. Acevedo, 500 U.S. 565 , 111 S. Ct. 1982 , 114 L.Ed.2d 619 (1991).

2017A few years later, the Court clarified that this exception was limited to “personal property . . . immediately associated with the person of the arrestee.” United States v. Chadwick, 433 U.S. 1, 15 , 97 S. Ct. 2476 , 53 L.Ed.2d 538 (1977) (200-pound, locked footlocker could not be searched incident to arrest), abrogated on other grounds by California v. Acevedo, 500 U.S. 565 , 111 S. Ct. 1982 , 114 L.Ed.2d 619 (1991).

2017A few years later, the Court clarified that this exception was limited to “personal property . . . immediately associated with the person of the arrestee.” United States v. Chadwick, 433 U.S. 1, 15 , 97 S. Ct. 2476 , 53 L.Ed.2d 538 (1977) (200-pound, locked footlocker could not be searched incident to arrest), abrogated on other grounds by California v. Acevedo, 500 U.S. 565 , 111 S. Ct. 1982 , 114 L.Ed.2d 619 (1991).

2017A few years later, the Court clarified that this exception was limited to “personal property . . . immediately associated with the person of the arrestee.” United States v. Chadwick, 433 U.S. 1, 15 , 97 S. Ct. 2476 , 53 L.Ed.2d 538 (1977) (200-pound, locked footlocker could not be searched incident to arrest), abrogated on other grounds by California v. Acevedo, 500 U.S. 565 , 111 S. Ct. 1982 , 114 L.Ed.2d 619 (1991).

2015However, in Young the court clarified that this standard no longer requires the alleged error to have been “sufficiently ‘egregious’ or ‘blatant’ [such] that the trial court should have acted sua sponte.” Id. at 726 n. 6 (clarifying Brewington v. State, 7 N.E.3d 946, 974 (Ind.2014)). [11] Indiana’s courts have recognized fundamental error in the context of probation revocation proceedings before.

1996In McCullough v. Archbold Ladder Co., 605 N.E.2d 175 (Ind.1993), this Court clarified the rule concerning disclosure of rebuttal witnesses and held that “the nondisclosure of a rebuttal witness is excused only when that witness was unknown and unanticipated; known and anticipated witnesses, even if presented in rebuttal, must be identified pursuant to a court order, such as a pre-trial order, or a proper discovery request.” Id. at 179 .

1996In McCullough v. Archbold Ladder Co., 605 N.E.2d 175 (Ind.1993), this Court clarified the rule concerning disclosure of rebuttal witnesses and held that “the nondisclosure of a rebuttal witness is excused only when that witness was unknown and unanticipated; known and anticipated witnesses, even if presented in rebuttal, must be identified pursuant to a court order, such as a pre-trial order, or a proper discovery request.” Id. at 179 .