Adams v. State
2012 Ind. LEXIS 14
| Ind. | 2012Background
- State trooper stopped Adams and Johnson for driving 94 mph on I-69; marijuana odor detected in the vehicle.
- Trooper observed a glass mason jar on the floorboard in the passenger area visible through the window; jar contained about 24 grams of marijuana.
- Adams claimed the jar and marijuana belonged to Johnson; Johnson claimed it belonged to him and that Adams did not know of it.
- Adams sat in the front passenger seat; the jar allegedly sat in front of him on the floorboard near his feet.
- Trial court convicted Adams of possessing marijuana and imposed a driver’s license suspension under Ind. Code § 35-48-4-15(a).
- Court of Appeals affirmed; Indiana Supreme Court granted transfer to address whether the license suspension statute applies when the defendant did not drive or own the vehicle.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the vehicle's use trigger § 35-48-4-15(a) for license suspension? | Adams argues no use by defendant; he rode in Johnson's vehicle, not using it. | Adams contends statute requires defendant's use of vehicle in the offense. | Yes; statute applies when defendant used the vehicle in the offense. |
| Must the defendant own or drive the vehicle for § 35-48-4-15(a) to apply? | Ownership or driving not required; any use suffices. | Only the defendant's use to contribute to the offense should trigger suspension. | Use by the defendant is required, but not necessarily ownership or driving; here Adams used the vehicle to possess marijuana. |
| How should the statute be interpreted textually and with legislative history? | Statute applies when any use by anyone occurs; broad interpretation. | Interpreting narrowly to require defendant's use aligns with the text and lenity. | Statute requires proof of defendant’s use of a vehicle in the offense; court applied the statute accordingly. |
Key Cases Cited
- Sloan v. State, 947 N.E.2d 917 (Ind. 2011) (statutory interpretation; ambiguity and de novo review for questions of law)
- State v. Oddi-Smith, 878 N.E.2d 1245 (Ind.2008) (textual analysis and interpretive approach for statutes)
- State v. Turner, 567 N.E.2d 783 (Ind.1991) (rule of lenity; ambiguity in criminal statutes resolved in defendant’s favor)
- Watson v. United States, 552 U.S. 74 (U.S. 2007) (use of object in committing offense; comparison on use)
- Smith v. United States, 508 U.S. 223 (U.S. 1993) (use of object in offense; broader interpretation of 'use')
- Serrano v. State, 946 N.E.2d 1139 (Ind.2011) (forfeiture requires proper nexus between vehicle and offense beyond incidental connection)
- Katner v. State, 655 N.E.2d 345 (Ind.1995) (forfeiture nexus principles; avoid incidental possession)
- Adams v. State, 960 N.E.2d 793 (Ind. 2012) (provided the controlling analysis in the decision)