Indiana Supreme Court
Patrick Austin, Appellant (defendant Below) v. State of Indiana, Appellee (plaintiff Below)
November 15, 20132013 Ind. LEXIS 900
Summary
The court held that the coordinated traffic stops and canine sweep leading to discovery of cocaine were reasonable under Article 1, section 11 of the Indiana Constitution because the officers had probable cause for the second stop, substantial individualized suspicion, and caused only minimal additional intrusion. It also held that the trial court properly denied Austin’s Criminal Rule 4(B) discharge motion because the court’s congestion finding was supported by the need to prioritize an earlier speedy-trial request and by the unavailability of a courtroom, jury, and witnesses. The court affirmed the convictions and sentence and summarily affirmed the Court of Appeals on all other issues.