Russell Finnegan v. State of Indiana

Summary

The Indiana Supreme Court held that Indiana’s statutory insanity-defense procedures do not apply to an indirect criminal contempt proceeding because such a proceeding is not a “criminal case” within the relevant statutes. The court relied on the statutory text, the separation between contempt and criminal procedures, and the different terminology and procedural structures used for each. It affirmed the contempt judgment, while recognizing that courts may consider a contemnor’s mental state and leaving any due-process challenge for a case in which it is properly raised.