Justia Indiana Supreme Court Opinion Summaries

When Sean and Dee Anna Ryan divorced, they agreed to sell two properties they owned and divide the proceeds, subject to a proviso that neither party was required to accept a sale yielding net proceeds below specified minimums. When the properties could not be sold at or above the specified minimums, Dee Anna refused to waive the proviso. Sean filed a motion for relief from judgment, seeking a court order that the properties be sold at prevailing fair market value and the private agreement be declared of no further force and effect. The trial court denied Sean's request. The Supreme Court affirmed the judgment of the trial court, holding (1) general rules applicable to contract construction dictated that Dee Anna was not required to agree to sell the properties for net proceeds less than the amounts set forth in the parties' agreement; and (2) Sean was not entitled to relief under Trial Rule 60(B), under which a court may relieve a party from a judgment. View "Ryan v. Ryan" on Justia Law

Plaintiff co-established Company. Plaintiff later sold his majority interest pursuant to an agreement calling for payments to Plaintiff and giving Plaintiff a security interest in Company's assets. Company subsequently applied for credit with Bank, which transaction made Plaintiff's security interest in Company's assets subordinate to Bank's. Thereafter, Company went out of business, leaving loans unpaid. Plaintiff brought claims against Bank for negligence, constructive fraud, actual fraud, and tortious interference with a contract. The trial court granted Bank's motion for judgment on the evidence on all claims, including finding that Bank owed no duty to Purcell. The court of appeals affirmed the trial court's ruling as to the issues of duty but reversed the trial court's judgment on the evidence as to Purcell's remaining claims. The Supreme Court granted transfer and affirmed the trial court, holding (1) there was not sufficient evidence presented in this case to withstand a motion for judgment on the evidence on Purcell's claims of fraud, deception, and tortious interference with a contract; and (2) Purcell's relationship with Bank as a subordinate creditor did not give rise to a duty of care required to prove Purcell's claims of negligence and constructive fraud. View "Purcell v. Old Nat'l Bank" on Justia Law

In this case, Plaintiff prevailed on its Access to Public Records Act (Act) claim against a public agency and an intervening private party. As required by statute, the trial court awarded Plaintiff attorney's fees. The fees were awarded against both the public agency and the intervening private party, jointly and severally. The private party argued that the Act does not contemplate the award of attorney's fees against an intervening private party and that only the public agency should be liable for the fees. The Supreme Court affirmed the trial court's award of attorney's fees to Plaintiff, holding (1) the Act, in light of the legislature's liberal-construction mandate and the statute's underlying policy, permits the award of attorney's fees against an intervening private party; and (2) in this case, the trial court did not abuse its discretion in its apportionment of liability. View "Shepherd Props. Co. v. Int'l Union of Painters & Allied Trades" on Justia Law

This case involved a property dispute between an individual church congregation, Olivet Presbyterian Church, and the denominational organization with which it was previously affiliated, the Presbyterian Church (U.S.A.), and the latter's subsidiary organizations, the plaintiffs in this action, the Presbytery of Ohio Valley and the Synod of Lincoln Trails of the Presbyterian Church (U.S.A.), Inc. (collectively, "Presbytery"). The trial court granted summary judgment rejecting the Presbytery's claims of express and implied trust and holding that the disputed property was solely owned by Olivet. The Presbytery appealed both the denial of its motion for summary judgment and the granting of Olivet's motion. The Supreme Court reversed, holding that genuine issues of material fact arose from the inferences flowing from the stipulated designated evidence and that neither Olivet nor the Presbytery was entitled to the full relief sought in their respective motions for summary judgment. Remanded. View "Presbytery of Ohio Valley, Inc. v. OPC, Inc." on Justia Law

Defendant was convicted of unlawful possession of a firearm by a serious violent felon and found to be a habitual offender. The court of appeals affirmed. The Supreme Court granted transfer, thereby vacating the opinion of the court of appeals. The Supreme Court vacated the habitual-offender enhancement, holding that the trial court erred in denying Defendant's motion to dismiss the habitual-offender allegation, as the habitual-offender enhancement to Defendant's sentence for unlawful possession of a firearm by an SVF constituted an impermissible double enhancement. The Court then affirmed Defendant's conviction of unlawful possession of a firearm by an SVF and his sentence for that offense. Remanded for resentencing. View "Dye v. State" on Justia Law

This case involved a seventeen-and-a-half-year-old who murdered his ten-year-old brother. Defendant confessed to the crime and pleaded guilty to murdering his brother, Conner, while he was babysitting. The trial court judge sentenced Defendant to life without parole. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court did not err in allowing the testimony of a medical doctor who suggested that Defendant had traits of a person with psychopathy; (2) the trial court properly weighed the aggravating and mitigating factors in this case; (3) based on the age of Conner, and the particularly heinous nature of the crime, a sentence of life without parole was appropriate under Indiana Appellate Rule 7(B); and (4) under the facts of this case, the imposition of a life-without-parole sentence on a person under the age of eighteen who has been convicted of murder did not violate either the United States or Indiana Constitution. View "Conley v. State" on Justia Law

Defendant was prosecuted for the death of her two-year-old cousin and later convicted of one count of murder, two counts of neglect of a dependent, one count of battery, and one count of misdemeanor false informing. Defendant was sentenced to life imprisonment without the possibility of parole for murder plus a total of five additional years for the other crimes. Defendant challenged her sentence on appeal. The Supreme Court revised Defendant's sentence, holding (1) the appropriate sentence for this defendant was sixty-five years, the maximum term of years for murder; and (2) the prosecutor committed misconduct in this case, but because Defendant's sentence was revised from life without parole to a term of sixty-five years, no further relief was warranted for Defendant's prosecutorial misconduct claim. Remanded. View "Castillo v. State" on Justia Law