A W v. State of Indiana

Summary

The court held that sufficient circumstantial evidence supported the juvenile adjudication for knowingly or intentionally possessing a machine gun because A.W. exclusively possessed a handgun fitted with a Glock switch and fled from officers. The court declined to decide whether Indiana's constitutional protection against successive prosecutions applies in juvenile proceedings, but held that the dangerous-possession adjudication violated substantive double jeopardy because it was an included offense of machine-gun possession arising from the same transaction. The court therefore affirmed the sufficiency ruling and reversed the dangerous-possession adjudication.