State v. Singleton

Summary

The court held that an indictment defect is jurisdictional only when the indictment wholly fails to charge a crime; deficiencies in alleging elements or providing sufficient detail are non-jurisdictional and subject to statutory remedies and prejudice requirements. It further held that the short-form indictment sufficiently charged second-degree forcible rape because it alleged vaginal intercourse with a physically helpless victim, and the State was not required to plead the defendant's knowledge of the victim's condition. The court therefore reversed the Court of Appeals.