Feb. 25, 2026

Indiana Court of Appeals
Isaiah Jerone Stokes v. State of Indiana
No. 25A-CR-531

Criminal. Appeal from the Marion Superior Court, Judges Marie Kern and James K. Snyder. Affirms Stokes’ conviction of Level 4 felony unlawful possession of a firearm by a serious violent felon. Holds the trial court did not abuse its discretion in admitting the handgun discovered during an inventory search of Stokes’ vehicle following his arrest on outstanding warrants at a gas station. Concludes the decision to impound the vehicle was authorized under Indianapolis-Marion County ordinances because Stokes could not move the vehicle due to his arrest and was also reasonable under the police’s community caretaking function, where the vehicle was parked at a busy gas pump during rush hour and the clerk wanted it removed. Further holds the inventory search was not pretextual, finding officers largely complied with IMPD’s tow policy and that minor deviations — including ultimately releasing the vehicle at the scene rather than completing the tow — did not render the search unreasonable under the Fourth Amendment or Article 1, Section 11 of the Indiana Constitution. Notes Judge Pyle dissented, concluding the inventory exception did not apply because the vehicle was never actually impounded. Appellant’s attorneys: Talisha Griffin; Jan B. Berg. Appellee’s attorney: Office of the Indiana Attorney General.

Indiana Court of Appeals
Rodregus Morgan v. State of Indiana
No. 25A-CR-836

Criminal. Appeal from the Marion Superior Court, Judge Marshelle Dawkins Broadwell. Reverses Morgan’s murder conviction and remands for a new trial. Holds the trial court abused its discretion in denying Morgan’s motion for a mistrial and subsequent motion to correct error after jurors were inadvertently given and considered his daughter’s deposition during deliberations. Explains the deposition — which had been admitted only for purposes of a pretrial Evidence Rule 404(b) ruling and excluded in part as overly prejudicial — contained allegations of Morgan’s long history of abuse and threats against the victim, including statements suggesting he had “a record” for abuse, physically assaulted her and previously threatened to kill her. Concludes the error was not harmless because the case turned on credibility between Morgan and the sole eyewitness, the deposition directly undermined Morgan’s character and credibility, corroborated the eyewitness’s account and supplied background evidence the trial court had excluded as more prejudicial than probative, and the court acknowledged jurors saw and considered the material. Determines the extraneous evidence likely had a probable persuasive effect on the verdict and therefore requires a new trial. Appellant’s attorneys: Talisha Griffin; Matthew D. Anglemeyer. Appellee’s attorney: Office of the Indiana Attorney General.

Indiana Court of Appeals
Ryan Gluys v. State of Indiana
No. 25A-CR-1488

Criminal. Appeal from the Rush Circuit Court, Judge Brian D. Hill. Reverses Gluys’s conviction of Class A misdemeanor invasion of privacy and remands for reconsideration under the correct legal standard. Holds Gluys waived his claim that he was entitled to a hearing before removal from his pretrial diversion program by failing to raise the issue before trial and did not demonstrate fundamental error, noting due process does not require a hearing before revocation of pretrial diversion. However, concludes the trial court relied on the wrong statutory definition of “harassment” when determining whether Gluys violated a protective order by emailing the mother of his child. Explains that invasion of privacy requires application of the civil definition of harassment in Indiana Code section 34-6-2-51.5 — which requires proof the conduct would cause a reasonable person emotional distress and actually caused the victim emotional distress — but the trial court instead quoted and applied the criminal harassment statute in Indiana Code section 35-45-2-2. Determines the presumption that a trial court knows and applies the correct law was rebutted by the court’s express reliance on the wrong statute, and declines to affirm on sufficiency grounds because it cannot prejudge how the trial court would have ruled under the proper standard. Appellant’s attorney: Cara Schaefer Wieneke. Appellee’s attorney: Office of the Indiana Attorney General.

The following opinion was issued after The Indiana Lawyer’s deadline on Feb. 24. 

Indiana Supreme Court
Michael Carr v. State of Indiana
No. 23S-LW-139

Criminal. Direct appeal from the Wayne Superior Court, Judge Gregory A. Horn. Affirms Carr’s murder conviction and life-without-parole sentence. Holds Carr failed to establish a violation of his Sixth Amendment right to a jury drawn from a fair cross-section of the community because, although African Americans are a distinctive group, he did not show systematic exclusion in Wayne County’s jury-selection process. Further holds the trial court did not err in admitting out-of-court statements by two unavailable witnesses under the forfeiture-by-wrongdoing doctrine, concluding Carr forfeited his confrontation rights by threatening to kill the witnesses and their families if they testified against him, and that the State made reasonable efforts to secure their attendance. Also holds the trial court did not abuse its discretion in admitting one witness’s statement to his sister as an excited utterance and that any alleged Confrontation Clause error was harmless in light of overwhelming evidence, including Carr’s own letters and admissions describing the killing. Concludes the trial court’s omission of a final Article 1, Section 19 instruction did not amount to fundamental error where the jury received the instruction preliminarily and was directed to consider all instructions together. Finally, declines to revise Carr’s life-without-parole sentence under Appellate Rule 7(B), finding the brutal, retaliatory nature of the offense and Carr’s character — including committing the murder while on parole — do not render the sentence inappropriate. Appellant’s attorney: Michael C. Cunningham. Appellee’s attorney: Office of the Indiana Attorney General.

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