Wadle v. StateAnnotate this Case
The Supreme Court expressly overruled the constitutional tests set forth in Richardson v. State, 717 N.E.2d 32 (Ind. 1999), in resolving claims of substantive double jeopardy and adopted an analytical framework that applies the statutory rules of double jeopardy.
The Richardson court adopted a comprehensive analytical framework constituting of a statutory elements test and an actual evidence test for deciding all substantive double jeopardy claims under Ind. Const. art. I, 14. Application of the tests, however, proved largely untenable, resulting in a patchwork of conflicting precedent and inconsistent standards. Defendant in this case was convicted of several offenses for leaving the scene of an accident after striking and injuring the victim while driving drunk. The Supreme Court overruled Richardson and adopted a framework that applies when a defendant's single act or transaction implicates multiple criminal statutes. The Court then held that Defendant's multiple convictions violated the statutory rules of substantive double jeopardy.