Justia Indiana Supreme Court Opinion Summaries

Brice Webb was charged with murder in the shooting death of his girlfriend. Webb requested a jury instruction on the lesser offense of reckless homicide. The trial court denied the request and Webb was convicted as charged. The Supreme Court reversed Webb's conviction and remanded the cause for a new trial, holding that the trial court's refusal to instruct the jury on the lesser-included offense of reckless homicide was reversible error, as the evidence in this case produced a serious evidentiary dispute concerning Webb's state of mind, and whether Webb acted knowingly or recklessly, that would justify giving the requested instruction. View "Webb v. State" on Justia Law

The trial court revoked the probation of Troy Smith for failure to pay weekly child support as a condition of his probation. On appeal, Smith argued that the State failed to carry its burden of proof that his failure to pay was reckless, knowing, or intentional. The Supreme Court affirmed the judgment of the trial court, holding (1) it is the defendant probationer's burden to show facts related to an inability to pay and indicating sufficient bona fide efforts to pay so as to persuade the trial court that further imprisonment should not be ordered; and (2) here, Smith failed to carry his burden, and therefore, the trial court did not abuse its discretion in revoking Smith's probation. View "Smith v. State" on Justia Law

The Indiana Department of Environmental Management (IDEM) informed Flexdar, Inc. that Flexdar would be liable for the costs of cleaning up trichloroethylene (TCE) contamination on a site where Flexdar previously had operations. State Automobile Mutual Insurance Company (State Auto), with whom Flexdar maintained general liability and umbrella insurance policies for the period when the contamination occurred, filed a declaratory judgment action, contending that coverage for the TCE contamination was excluded pursuant to a pollution exclusion in the policies. The trial court entered summary judgment in favor of Flexdar, concluding that the language of State Auto's pollution exclusion was ambiguous and therefore should be construed against State Auto and in favor of coverage. The Supreme Court affirmed, holding that the language of the pollution exclusion at issue was ambiguous, and therefore, in accordance with precedent, the policies were construed in favor of coverage. View "State Auto. Mut. Ins. Co. v. Flexdar, Inc." on Justia Law

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services. View "Perdue v. Gargano" on Justia Law

An employee of a concrete subcontractor was injured in a workplace accident during the construction of a stadium. The employee sought to recover damages for negligence from the project's construction manager by whom she was not employed but whom she contended had a legal duty of care for jobsite-employee safety. The trial court ruled in the employee's favor that the construction manager could be held vicariously liable for the actions of the subcontractor. The Supreme Court granted transfer and reversed the trial court, holding (1) the construction manager was not vicariously liable to the worker for any negligence of the subcontractor because the construction manager and subcontractor did not have the requisite relationship; and (2) the construction manager did not have, either by the terms of its contracts or by its actions, a legal duty of care for jobsite-employee safety, and therefore the construction manager could not be held liable to the employee for negligence. Remanded. View "Hunt Constr. Group, Inc. v. Garrett" on Justia Law

John Witt, HydroTech Corporation, and attorney Mark Shere (Appellants) were held in contempt of court for violating the terms of a temporary restraining order (TRO). The contempt holding arose from protracted litigation in a lawsuit over the costs of an environmental cleanup. The trial court issued the TRO enjoining work on the site until a preliminary injunction hearing could be held. After the TRO was issued, work on the site commenced. The trial court subsequently issued the preliminary injunction. Later, the court held Appellants in contempt and held them jointly and severally liable for $108,487 in costs and attorneys' fees. The Supreme Court granted transfer and affirmed the trial court, concluding that the trial court did not err in holding Witt, Shere, and HydroTech in contempt, determining the sanction, and imposing it jointly and severally. View "Witt v. Jay Petroleum, Inc." on Justia Law

The State entered into a contract with IBM, and the Governor signed the contract. IBM later terminated the contract, after which the State filed suit against IBM asserting breach of contract among other claims. IBM then served notice on the Governor to take his testimonial deposition. The State moved for a protective order, asserting that the Governor's deposition was prohibited based on the Governor's unqualified privilege from arrest on civil process, and from obeying any subpoena to testify, pursuant to Ind. Code 34-29-2-1. The trial court granted IBM's motion with certain limitations. The Supreme Court reversed, holding that the statute clearly precludes a deposition of a sitting Governor. The privilege afforded by the statute is absolute, the Court stated, and once it is invoked, any party protected by the privilege may not be compelled to give testimony. View "State v. Int'l Bus. Machines Corp." on Justia Law

A jury found Rodney Nicholson guilty of stalking and harassment, and Nicholson admitted to being a habitual offender. A majority of the court of appeals held that a span of twenty-two months between contacts would not fit the definition of repeated or continuing harassment and therefore would not support a conviction for stalking. The Supreme Court granted transfer and affirmed the trial court, holding that the lag in time between the harassing calls in 2006 and subsequent single call in 2008 did not foreclose the conviction for stalking, as there was no statutorily determine timeframe required for a stalking conviction and there was sufficient evidence for the trier of fact to determine Nicholson engaged in stalking. View "Nicholson v. State" on Justia Law

After Sawmill Creek's taxes became delinquent on its property, the Marion County Auditor set the property for tax sale. A tax deed was issued to McCord Investments upon the petition of the Auditor following the one-year redemption period after a tax sale. The trial court ultimately set aside the tax deed on grounds that the Auditor's effort to notify Sawmill of the tax sale was constitutionally deficient for failing to meet the requirements of due process. The Supreme Court reversed, holding that the notices of the tax sale and of Sawmill's right to redeem did not violate due process because, under the Mullane v. Cent. Hanover Bank & Trust Co. standard, the Auditor's actions were reasonably calculated to provide notice to Sawmill. View "Marion County Auditor v. Sawmill Creek, LLC" on Justia Law

Stephan Odders and Gerald Kerber were former employees of Loparex, a corporation in the release liner industry. Both employees were subject to a one-year noncompetition agreement upon termination of employment. After ceasing employment at Loparex, both employees began employment with MPI Release Technologies, a competitor in the release liner industry. Loparex sued Kerber and Odders (Defendants) in the U.S. district court, seeking injunctive relief under the Illinois Trade Secrets Act and damages resulting from Defendants' breach of the noncompetition agreement. Defendants filed amended answers and counterclaims accusing Loparex of blacklisting in violation of Indiana law. The Supreme Court accepted certification to answer questions of state law and held (1) Wabash Railroad Co. v. Young, which held that Indiana's Blacklisting Statute did not provide a cause of action to individuals who voluntarily leave their employment, is no longer good law and individuals who voluntarily leave employment are not barred from making a claim under the Blacklisting Statute; (2) attorney fees are not an element of compensatory damages under the Blacklisting Statute; and (3) an employer's suit against a former employee to protect trade secrets is not a basis for recovery under the Blacklisting Statute. View "Loparex, LLC v. MPI Release Techs., LLC" on Justia Law