Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with Class A felony manufacturing methamphetamine - enhanced from a Class B felony because at least three grams of the drug were at issue. The State relied significantly on a liquid solvent that contained methamphetamine to support the three-gram weight enhancement. A jury found Defendant guilty of the Class A felony methamphetamine offense. Defendant appealed, arguing that the evidence was insufficient to support the three-gram weight enhancement. The Supreme Court affirmed, holding (1) when the State seeks to establish the weight of manufactured methamphetamine based on an intermediate mixture that contains methamphetamine, it must demonstrate how much final product that mixture would have yielded had the defendant finished the manufacturing process; (2) because the State failed to present this evidence, it could not use the intermediate mixture to establish the three-gram weight enhancement for Class A felony manufacturing methamphetamine; but (3) because the record showed that Defendant manufactured additional final product that exceeded the three-gram threshold, the evidence was sufficient to sustain Defendant’s conviction. View "Buelna v. State" on Justia Law

The Indiana Department of Insurance Commissioner reviewed the practices of First American Title Insurance Company, resulting in the generation of a report. Six weeks after the deadline for taking action regarding the report, the Commissioner called for a hearing and appointed an administrative judge. First American filed a petition seeking judicial review of the Commissioner’s order. The Commissioner moved to dismiss the petition on grounds that First American failed to submit the agency record as required by the Administrative Orders and Procedures Act (AOPA). The trial court denied the Commissioner’s motion to dismiss but also denied First American’s petition for judicial review on grounds that First American failed to show that it was prejudiced by the untimely order. Both parties appealed. On cross-appeal, the Commissioner argued, in part, that First American’s petition for judicial review should have been dismissed because First American did not submit an agency record. The Supreme Court reversed, holding that the trial court erred in declining to grant the Commissioner’s motion to dismiss the petition in light of First American’s failure to file the agency record with the trial court, as a petitioner for review cannot receive consideration of its petition where the statutorily-defined agency record has not been filed. View "First Am. Title Ins. Co. v. Robertson" on Justia Law

One year after the Indiana Department of Education and the Indiana State Board of Education (collectively, “DOE”) approved Teaching Our Posterity Success, Inc. (“TOPS”) as a Supplemental Educational Services provider, the DOE removed TOPS from its list of approved providers. TOPS sought administrative review of that removal. In response, DOE sent TOPS a letter declaring that TOPS will remain removed from the provider list. TOPS filed a petition for judicial review but did not file an official agency record. The trial court dismissed TOPS’ petition on the grounds of its failure to file a timely and complete agency record. The Supreme Court affirmed, holding (1) a petitioner seeking judicial review of an agency action must file with the trial court the agency record as defined by the Administrative Orders and Procedures Act (AOPA); and (2) because TOPS did not file the agency record as anticipated by the AOPA, the trial court properly dismissed its petition for judicial review. View "Teaching Our Posterity Success, Inc. v. Ind. Dep’t of Educ." on Justia Law

Plaintiffs, an exclusive-agency union and several of its members and officers (collectively, the Union), filed a complaint against the Attorney General and the Commissioner of the Indiana Department of Labor (collectively, the State), seeking a declaratory judgment that certain provisions of the Indiana Right to Work Law were unconstitutional. The trial court granted relief on the Union’s claim that two provisions of the Indiana Work Law violated Article 1, Section 21 of the Indiana Constitution, which provides that “[no] person’s particular services shall be demanded, without just compensation.” The first challenged provision of the Indiana Work Law prohibits employers from requiring union membership or the payment of monies as a condition of employment, and the second provision makes the knowing or intentional violation of the first provision a Class A misdemeanor. The Supreme Court reversed, holding that the two provisions do not violate Section 21 because the challenged provisions do not constitute a demand by the State for particular services. View "Zoeller v. Sweeney" on Justia Law