Justia Indiana Supreme Court Opinion Summaries

After a 911 call was made by a motorist complaining that the driver of a blue Volkswagen, who had just pulled into a gas station, was driving erratically, a police officer arrived at the gas station and observed the blue Volkswagen. The officer then made an investigatory stop of the driver of the vehicle, Amanda Renzulli. Renzulli was later charged with operating a vehicle while intoxicated. The trial court granted Renzulli's motion to suppress the evidence on the grounds that there was no reasonable suspicion for the stop. The Supreme Court reversed, holding that, based on the totality of the circumstances, the police officer in this instance had reasonable suspicion based on articulable facts to briefly detain Renzulli for investigatory purposes. View "State v. Renzulli" on Justia Law

In this case, the State sought to enforce a particular provision of the Indiana Autodialer Law against an entity that used an automated dialing device to deliver prerecorded political messages. The trial court, on cross-motions for preliminary injunction, decided that the entity had a reasonable likelihood of success on the merits of its claim that the live-operator requirement of the Autodialer Law violated the free speech clause of the Indiana Constitution. The Supreme Court reversed, holding (1) the entity's First Amendment claim would likely fail, and (2) there was no reasonable likelihood of success on the merits of the entity's claim that the Autodialer Law's live-operator requirement materially burdened its right to engage in political speech in violation of the state Constitution. Remanded. View "State v. Econ. Freedom Fund" on Justia Law

After Employee was unable to successfully complete her necessary training, Employer gave her the option to resign immediately or to be placed on a thirty-day unpaid leave of absence. Employee opted to resign immediately and thereafter sought unemployment insurance benefits. The Department of Workforce Development denied Employee's application for benefits on the grounds the Employee voluntarily left employment and did so without good cause. An ALJ concluded (1) Employee did not voluntarily quit her position but was constructively discharged, and (2) Employee was disqualified from receiving benefits because she had breached a duty reasonably owed to her employer, which breach constituted just cause for her termination. The Unemployment Insurance Review Board adopted and approved the ALJ's decision. The Supreme Court affirmed the denial of Employee's claim, holding (1) the Board's finding that Employee breached a duty reasonably owed to Employer was reasonable; and (2) it was reasonable for the Board to find that Employee was discharged for just cause and was therefore ineligible for benefits. View "Recker v. Ind. Dep't of Workforce Dev. Review Bd." on Justia Law

Respondent, a judge of the city court, dismissed the traffic infraction cases of all litigants who attended traffic school and paid the applicable fee. Respondent also entered default judgment, imposed fines and court costs, and ordered the suspension of driver's licenses of all litigants who selected traffic school but failed to complete the class. Respondent, however, had no authority to discharge traffic infraction cases without a specific request from the prosecuting attorney or to divert litigants' cases through a de facto deferral program not authorized by the county prosecutor. The Indiana Commission on Judicial Qualifications then brought a judicial disciplinary action against Respondent. Respondent and the Commission agreed that by referring traffic infraction litigants to the traffic school and then dismissing their cases upon their completion of the program without any dismissal request from the prosecutor, Respondent abused his judicial authority, committed conduct prejudicial to the administration of justice, and violated the Code of Judicial Conduct's provisions that required him to comply with the law. As a sanction for this misconduct, the Supreme Court suspended Respondent from office without pay for a period of sixty days. View "In re Judge Harkin " on Justia Law

The Indiana Constitution authorizes the General Assembly to disenfranchise "any person convicted of an infamous crime." Plaintiff was convicted of misdemeanor battery. During his incarceration, Plaintiff was informed that his voter registration was canceled in accordance with several provisions of state law under which persons convicted of crimes and sentenced to imprisonment are disenfranchised for the duration of incarceration. After his release, Plaintiff filed a lawsuit seeking declaratory and injunctive relief against state and county election officials. The Supreme Court accepted certification to answer whether Plaintiff's constitutional rights were violated when his voter registration was canceled because, as Plaintiff alleged, misdemeanor battery was not an "infamous crime." The Court held (1) the crime in this case was not an "infamous crime," but (2) the General Assembly has separate constitutional authority to cancel the registration of any person incarcerated following conviction for the duration of the incarceration, and (3) therefore, Plaintiff's Constitutional rights were not violated when he was disenfranchised while incarcerated. View "Snyder v. King" on Justia Law

Following the death of their full-term baby daughter in utero during labor, Plaintiffs brought an action against the hospital, the Plaintiffs' nurse-midwife, and the nurse-midwife's alleged employer for negligent infliction of emotional distress. The trial court granted summary judgment to Defendants. The court of appeals reversed. The Supreme Court granted transfer and reversed the trial court, holding (1) Plaintiffs' claims were not precluded by the Indiana Child Wrongful Death Act; (2) Plaintiffs were not precluded from maintaining an action for emotional distress under the bystander rule; and (3) Plaintiffs' actions were not barred by the Indiana Medical Malpractice Act. Remanded. View "Spangler v. Bechtel" on Justia Law

Appellant was charged with tattooing a minor for taking his former Stepdaughter to get a tattoo. While the charge was pending, a detective arranged for Stepdaughter to make recorded phone calls to Appellant to obtain evidence concerning a sexual relationship Appellant allegedly forced upon Stepdaughter. The State subsequently charged Appellant with several sex-related crimes. Appellant moved to suppress the incriminating statements from the conversations, claiming they were obtained in violation of his right to counsel. The trial court denied the motion and convicted Appellant as charged. The court of appeals affirmed. At issue before the Supreme Court was whether an "inextricably intertwined" exception to the offense-specific nature of the right to counsel existed under the state Constitution. The Court affirmed, holding (1) under the Indiana Constitution, the right to counsel is violated only where the different offense is inextricably intertwined with the charge on which counsel is already representing the defendant; and (2) because there was no evidence that it would have been objectively foreseeable for the detective, at the time he conducted the phone calls, to believe the pending tattooing offense was inextricably intertwined with the alleged sexual misconduct, the recorded conversations did not violate Appellant's right to counsel. View "Jewell v. State" on Justia Law