Justia Indiana Supreme Court Opinion Summaries

Appellant pled guilty to driving while intoxicated after proceeding pro se in plea negotiations with the State. Appellant filed a petition for postconviction relief, alleging that his waiver of counsel was invalid. The trial court denied the petition. The Supreme Court granted transfer and announced that future defendants expressing a desire to proceed without counsel must be informed that an attorney is more experienced in plea negotiations and better able to identify and evaluate potential defenses and problems in the prosecution's case (Hopper warning). The Court subsequently granted the State's petition for rehearing and affirmed the post-conviction court, holding (1) the Sixth Amendment does not require the same warnings and analysis for a valid waiver of counsel during plea negotiations as it requires for the entry of a guilty plea; (2) the post-conviction court properly found that Hopper's waiver of counsel during his guilty plea hearing was voluntary and intelligent; and (3) the absence of the Hopper warning is not a per se violation of a defendant's right to counsel, but rather, courts should consider the absence of the instruction as an additional factor in a totality of the circumstances approach. View "Hopper v. State" on Justia Law

Washington Township and the West Central Conservancy District (WCCD) owned property within the Town of Avon's boundaries that overlay an underground aquifer. After the Township and WCCD began exploring the possibility of drilling wells into the aquifer in order to withdraw water and sell it to third parties, the Town passed an ordinance that (1) prohibited taking water from a watercourse for retail, wholesale, or mass distribution unless done on behalf of the Town, and (2) defined a watercourse as any body of water whether above or below ground. The Township and WCCD filed complaints challenging the ordinance's validity under the state's Home Rule Act. The trial court granted summary judgment for the Township and WCCD. The court of appeals affirmed. The Supreme Court reversed, holding (1) the aquifer at issue was a watercourse under Indiana law; (2) the Home Rule Act permitted the Town to regulate another political unit's attempt to withdraw water from the aquifer; and (3) the Town's proposed regulation was not preempted by statutes authorizing the Department of Natural Resources to regulate aquifers. View "Town of Avon v. W. Cent. Conservancy Dist." on Justia Law

A trial court found Lisa Gray guilty of possessing marijuana as a class A misdemeanor. The court of appeals set aside the conviction on the grounds of insufficient evidence. At issue on appeal was whether the trial court properly found Gray had constructive possession of the marijuana when it was found on the floor of her apartment and Gray's son testified that the marijuana belonged to him. The Supreme Court granted transfer, vacated the court of appeals, and affirmed the trial court, holding that there was substantial evidence of probative value from which the court could have found beyond a reasonable doubt that Gray committed the crime. View "Gray v. State" on Justia Law

Appellant Indiana Spine Group provided medical services to employees of various businesses for injuries the employees sustained arising out of and during the course of their employment. The employers authorized the services and made partial payments. In each case, more than two years after the last payments were made to the injured employee, Appellant filed with the worker's compensation board an application for adjustment of claim seeking the balance of payments. The Board dismissed the applications as untimely. In each case the court of appeals reversed and remanded. At issue on appeal was what limitation period was applicable to a medical provider's claim seeking payment of outstanding bills for authorized treatment to an employer's employee when the Worker's Compensation Act was silent on the question. The Supreme Court reversed the Board, holding (1) the limitation period contained in the general statute of limitation enumerated in Ind. Code 34-11-1-2 controlled; and (2) because Appellant's claim was timely under the statute, the Board erred by dismissing Appellant's application. View "Indiana Spine Gp., PC v. Pilot Travel Ctrs., LLC" on Justia Law

When he was fourteen years old, D.C. and three other boys broke into the home of an elderly woman, ransacked the home, and injured the homeowner. At a dispositional hearing, the juvenile court imposed on D.C. a determinate commitment of two years at the Department of Correction to be followed by an indeterminate commitment. D.C. appealed the dispositional order, arguing that the juvenile court incorrectly ordered both a determinate commitment and indeterminate commitment. The court of appeals agreed and reversed in part and remanded with instructions that the juvenile court impose a determinate commitment only. The Supreme Court granted transfer and reversed the trial court's dispositional order, holding that the determinate and indeterminate commitment statutes in question were unambiguously mutually exclusive, and thus the trial court could impose only one of the commitments on D.C. Remanded to the trial court to decide, in its discretion, which type of commitment was appropriate. View "D.C. v. State" on Justia Law