Christina M. Kovats v. State of Indiana

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that misdemeanor OWIs are lesser included offenses of a felony OWI
• noting that maximum possible sentences are generally reserved for the worst offenders
• noting that vacating conviction constituting double jeopardy cures the double jeopardy problem
• noting that “if the trial court does enter judgment of conviction [on two offenses barred by double jeopardy principles] . . . then simply merging the offenses [for the purposes of sentencing] is insufficient and vacation of the offense is required”
• If a trial court does not formally enter a judgment of conviction on a jury verdict of guilty, then there is no requirement that the trial court vacate the conviction, and merger is appropriate to cure any double jeopardy issues
• remanding for trial court to vacate improperly merged conviction

Source: CourtListener parenthetical corpus (CC0).