id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-27446	Chinn, Scott; Pulliam, Daniel E.; Gutwein, Stephanie L.; Little, Elizabeth M.	Separation of Powers: Indiana Constitutional Law to the Forefront -- 2021-2022	2023	24	.pdf	application/pdf	10877	652	62	Rather, the argument contradicted Indiana Supreme Court authority that determining the degree of privacy interest sufficient to confer standing is determined on a case- by-case basis.60 In Ramirez v. State, the Indiana Supreme Court held that a warrantless seizure of a security camera recorder was reasonable under Article 1, Section 11’s totality of the circumstances test.6 1 The degree of suspicion was high because law enforcement could see on the monitor connected to the recorder that the security camera displayed live surveillance footage with a clear view of the driveway of a home where a toddler was found dead of what was later determined to be multiple blunt force injuries.62 The footage could be “clearly critical” to the investigation and potentially corroborate the timing of when the suspect arrived at the home.63 The seizure of the recorder did not limit anyone’s movements and law enforcement obtained a search warrant before viewing the footage lowering the degree of the intrusion.64 Finally, leaving the home to obtain a search warrant could have compromised the evidence given that the owners of the home were not detained, and electronically stored evidence may be easily destroyed.65 Given these factors, the seizure of the device did not violate the Indiana Constitution.66 The court also found that under Article 1, Section 16, the defendant’s offense was so severe that his sentence of life without parole was not disproportionate even though the jury found that he had committed the murder knowingly but not intentionally.67 A life sentence without the possibility of parole was proportional and graduated to the brutal murder of a toddler, who was put in his care, that 55. The Indiana Supreme Court affirmed the trial court.259 “Our Constitution guarantees the citizens of Indiana	cache/inlawrev-27446.pdf	txt/inlawrev-27446.txt