Justia Indiana Supreme Court Opinion Summaries

Pursuant to a plea agreement, Antoine Hill pleaded guilty to one count of Class A felony attempted murder and two counts of Class C felony attempted battery. Hill did not appeal. Hill's counsel subsequently filed a Post-Convcition Rule 2 petition, seeking permission to file a belated notice of appeal. The trial court denied permission, and counsel did not timely appeal this denial. Thereafter, Hill, through different counsel, filed a Post-Conviction Rule 1 petition, alleging that his Post-Conviction Rule 2 counsel was ineffective for failing to timely appeal the trial court's denial of permission to file a belated notice of appeal. The trial court denied the petition, concluding that Hill could not satisfy the ineffective-assistance-of-counsel test set forth in Strickland v. Washington. The Supreme Court affirmed but on different grounds, holding (1) the appropriate standard for judging the performance of Post-Conviction Rule 2 counsel is the standard set forth in Baum v. State; and (2) Post-Conviction Rule 2 counsel in this case did not violate Baum because she represented Hill in a procedurally fair setting that resulted in a judgment of the court. View "Hill v. State" on Justia Law

Robin Everhart filed suit against the Indiana Patient's Compensation Fund (PCF) to recover excess damages after settling a wrongful death claim against an emergency room physician in whose care her husband died. The PCF asked the trial court to reduce its award of damages to account for the twenty percent change that Robin's husband would have died anyway, even in the absence of the physician's negligence. The trial court declined to do so, awarding Robin the statutory maximum of $1 million in excess damages. The Supreme Court affirmed but on slightly different grounds, holding that the PCF was required to pay the statutory maximum in excess damages and was not entitled to a set-off because of how the trial court's peculiar findings of fact interacted with the rules for calculating a set-off. View "Ind. Dep't of Ins. v. Everhart" on Justia Law

In 2008, Chrysler offered a buyout program to employees in Kokomo, Indiana. Those employees then applied for unemployment benefits under Indiana's Unemployment Compensation Act. The Indiana Department of Workforce Development denied the claims. The Review Board of the Indiana Department of Workforce Development ultimately awarded benefits under a narrow provision of the Act. The court of appeals reversed, holding that the Board's application of the provision was erroneous and inconsistent with the statute. The Supreme Court granted transfer and vacated the court of appeals. The Court then affirmed the decision of the Board, holding that the Board properly applied the law to its findings of fact, and the Board's conclusion that the employees were eligible for benefits was reasonable in light of the evidence before it. View "Chrysler Group, LLC v. Review Bd. of the Dep't of Workforce Dev." on Justia Law

After an automobile collision in which Travis Becker struck Rickey Whitaker, Whitaker filed suit for personal injuries. Thereafter, Whitaker's lawyer ignored repeated requests to provide information about his client's medical treatment, responded only after the trial court ordered him to do so, and then supplied false and misleading information in a way that damaged Becker's ability to ascertain the facts necessary to litigate the case. Becker's counsel filed a motion for sanctions. The trial court found that Whitaker and his lawyer had acted in bad faith and dismissed the case. The Supreme Court affirmed the trial court, holding that the court acted within its discretion in making it clear to counsel that this type of behavior was unacceptable. View "Whitaker v. Becker" on Justia Law

A.T. was adjudicated delinquent for an act that would be felony murder if committed by an adult, and the juvenile court ordered both a determinate and an indeterminate commitment to the department of correction. A.T. appealed his determinate commitment only, and the court of appeals affirmed. The Supreme Court granted transfer and reversed the trial court's dispositional order, holding that because A.T. did not meet the criteria of Ind. Code 31-37-19-9(b), which provides that a determinate commitment may be imposed for juveniles who are sex or violent offenders, a determinate commitment under that section should not have been imposed. Remanded with instructions to vacate the portion of the court's order committing A.T. to the department of correction until his eighteenth birthday. View "A.T. v. State" on Justia Law

Plaintiff sued Defendants, a doctor and hospital, for medical malpractice. Defendants filed motions for a preliminary determination requesting that the trial court dismiss the complaint due to Plaintiff's dilatory conduct. The trial court denied the request. The court of appeals (1) determined that the trial court's order was a final judgment, and (2) affirmed the trial court's order as to the hospital but reversed as to the doctor. The Supreme Court granted transfer and dismissed the appeal for lack of subject matter jurisdiction, holding that the trial court's order was not a final appealable judgment because it did not dispose of all claims as to all parties and because the trial court's order did not contain the "magic language" of Ind. R. App. P. 2(H)(2). View "Ramsey v. Moore" on Justia Law

A jury convicted Defendant of Class A felony neglect of a dependent and found him to be a habitual offender, which resulted in a thirty-year sentencing enhancement. The court of appeals affirmed. On transfer to the Supreme Court, the State presented an unsigned judgment of conviction to prove that Defendant in fact had been convicted of one of the predicate felonies. The Court vacated the court of appeals in regard to Dexter's claim that the evidence was insufficient to support the jury's finding that he was a habitual offender and affirmed in all other respects, holding (1) an unsigned judgment was not sufficient to prove beyond a reasonable doubt the fact of a prior conviction, and therefore, Defendant's habitual-offender sentencing enhancement must be reversed; and (2) the Double Jeopardy Clause did not bar the State from retrying Defendant on the habitual-offender enhancement. View "Dexter v. State " on Justia Law

Players on a local youth soccer team sought to recover under the state youth soccer governing association's business auto-insurance policy for injuries sustained when the van in which they were riding was involved in an accident. The trial court granted summary judgment in favor of the association's insurance carrier. The court of appeals affirmed, holding that under the relevant insurance policy language, the rented van was not being used in the business of the association at the time of the accident. The Supreme Court granted transfer and affirmed the trial court, holding that because Castro was not using the automobile "in the business" of the association, a condition for coverage under the insurance policy at issue, the policy provided no coverage to the injured players. View "Haag v. Castro" on Justia Law