Court of Appeals of Indiana
James Easter, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff
No. 25A-CR-1229
Appeal from Marion Superior Court, Judge James K. Snyder. James Easter was convicted of multiple crimes, including rape by force and rape by disregarding refusal, after assaulting his ex-girlfriend. He appealed the convictions on the grounds that they constituted substantive double jeopardy. The court found that both rape counts were based on the same act of oral sex, thus applying the framework from a recent Supreme Court decision, which concluded that his dual convictions for rape amounted to a single offense. Additionally, the court determined that his conviction for criminal confinement also violated the double jeopardy doctrine since the State could not demonstrate that the confinement was separate from the force used during the rape. Consequently, the convictions for rape by disregarding refusal and criminal confinement were vacated, and the case was remanded for correction. Judge Weissmann authored the opinion, with Judge Bradford and Judge DeBoer concurring. Appellant’s attorney: Ellen M. O’Connor, Marion County Public Defender Agency, Indianapolis, Indiana. Appellee’s attorney: Office of the Indiana Attorney General.
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