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Law. He is also a former Editor-in-Chief of the Indiana Law Review and The Butler Collegian and a former law clerk for Judge John Daniel Tinder on the U.S. Court of Appeals for the Seventh Circuit. *** Stephanie Gutwein is a partner in the business litigation group at Faegre Drinker Biddle

Although the last few years produced minimal developments in Indiana constitutional law, 1 this survey period, the Indiana appellate courts used their constitutional powers to pragmatically address issues associated with the COVID-19 pandemic and to clarify the test for constitutional double jeopardy violations.In 2020, the COVID-19 pandemic and disciplinary proceedings against Indiana's former Attorney General led the Indiana Supreme Court to address three cases concerning its original jurisdiction. The Indiana Supreme Court invoked its original jurisdiction to adopt emergency court rules protecting stimulus payments received under the federal Coronavirus Aid, Relief, and Economic Security ("CARES") Act. But it concluded it did not have original jurisdiction to direct the actions of local prisons and jails as to detained, jailed, and incarcerated individuals whose livelihoods COVID-19 threatened.And after more than twenty years of occasionally inconsistent results, the Indiana Supreme Court overruled the Richardson constitutional tests for resolving claims of substantive double jeopardy and limited the reach of Indiana's double