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Indiana Supreme Court
State of Indiana v. Bryan D. Lyons
23S-CR-163
Criminal. Grants transfer and affirms the suppression of incriminating statements Bryan D. Lyons made immediately after a polygraph that was changed to a “non-stipulated,” inadmissible investigatory examination without disclosure to the state. Finds that before excluding evidence as a Trial Rule 37 discovery sanction, a trial court must find that the exclusion is the sole remedy available to avoid substantial prejudice or that the sanctioned party’s culpability reflects an egregious discovery violation. Also finds the Lawrence Superior Court’s order in Lyons’ case enforced Trial Rule 37 within those limits.

Indiana Supreme Court
S.D. v. G.D.
23S-PO-89
Protective order. Affirms the issuance of a two-year protective order against father S.D., with the Starke Circuit Court finding that mother G.D. had established that “domestic or family violence” occurred and that father “represents a credible threat to the safety” of G.D. and child H.D. Finds the trial court’s evidence-based findings support its judgment issuing a protective order against S.D.