Justia Indiana Supreme Court Opinion Summaries

The Hoagland Family Limited Partnership and its partners have been involved in a legal dispute with the Town of Clear Lake regarding a sewage hookup since 2010. This ongoing litigation is under case number 76C01-1006-PL-425 in the Steuben Circuit Court. In 2023, Hoagland filed a new complaint in the Steuben Superior Court (case number 76D01-2305-PL-237) against the Town and various associated parties. The claims in this new case were based on the same facts and circumstances as the ongoing case. Consequently, the superior court dismissed the new complaint under Trial Rule 12(B)(8), which addresses the issue of the same action pending in another state court.The Steuben Superior Court dismissed the new case with prejudice, meaning that Hoagland would be precluded from bringing the same claims again. Hoagland did not contest the dismissal itself but argued against the dismissal being with prejudice. The Indiana Court of Appeals affirmed the superior court's decision.The Indiana Supreme Court reviewed the case and found that the superior court erred in dismissing the case with prejudice. The Supreme Court noted that a dismissal with prejudice is akin to a judgment on the merits and precludes relitigation of the claims. The court emphasized that Hoagland should not be prematurely denied the opportunity to litigate its claims. Therefore, the Indiana Supreme Court vacated the Court of Appeals' opinion and remanded the case to the superior court with instructions to dismiss the case without prejudice. This allows Hoagland the possibility to pursue its claims in the ongoing litigation in the Steuben Circuit Court. View "Hoagland Family Limited Partnership v. Town of Clear Lake" on Justia Law

Christopher Nardi submitted an APRA request to the Indiana Election Division for documents related to Indiana’s voter-registration system. He requested three specific documents: the latest standard operating procedures, build notes, and the latest contract with third-party vendors. The Division denied the requests, citing security concerns, but directed Nardi to an online portal for the contract, which he accessed but failed to save. Nardi then filed a complaint with Indiana’s Public Access Counselor (PAC), which recommended partial disclosure. The Division refused, leading Nardi to file a lawsuit in Marion Superior Court.The Marion Superior Court conducted an in-camera review and ordered the Division to provide a redacted version of the contract but denied the other requests. Nardi petitioned for attorney’s fees, claiming he substantially prevailed. The trial court awarded him one-third of the requested fees, reasoning he prevailed on one of three requests. Both parties appealed. The Indiana Court of Appeals affirmed the partial summary judgment but reversed the fee award, concluding Nardi did not substantially prevail.The Indiana Supreme Court reviewed the case, holding that Nardi substantially prevailed by obtaining a wrongfully withheld public record. The Court found that the trial court did not abuse its discretion in this determination. However, the Supreme Court reversed the trial court’s mechanical reduction of attorney’s fees to one-third. The case was remanded for the trial court to recalculate the fees, considering the time spent on the successful claim and whether the time spent on unsuccessful claims was indivisible from the successful claim. The Indiana Supreme Court emphasized that APRA should be liberally construed to promote transparency and accountability in government. View "Nardi v. King" on Justia Law

A fifteen-year-old, J.Q.R., sold fentanyl-laced pills to two classmates, B.H. and R.J., resulting in R.J.'s death from an overdose. During the investigation, police discovered evidence implicating J.Q.R.'s father in illegal drug activities. The father waived J.Q.R.'s Miranda rights twice, leading to J.Q.R. making incriminating statements to the police.The Hendricks Superior Court admitted J.Q.R.'s statements into evidence over his objections, arguing that his father had an adverse interest due to his own criminal conduct. The court adjudicated J.Q.R. as a delinquent child. The Indiana Court of Appeals affirmed the trial court's decision.The Indiana Supreme Court reviewed the case and held that an adverse interest may arise if an adult stands to personally benefit from waiving a child's rights to the child's detriment. The court found that the State failed to prove beyond a reasonable doubt that the father had no adverse interest when he waived J.Q.R.'s rights, given the evidence of the father's own drug activities. Therefore, the trial court erred in admitting J.Q.R.'s statements.However, the Indiana Supreme Court concluded that the error was harmless because independent evidence, such as text messages, established that J.Q.R. knew the pills contained fentanyl. Consequently, the court affirmed the trial court's adjudication of J.Q.R. as a delinquent child. View "J.Q.R. v. State" on Justia Law

Zachariah Konkle, a ride operator at a traveling carnival, was involved in an altercation with Michael Steele, a game operator, at the Jackson County Fair. The conflict arose after Konkle learned that a game operator had mocked a child with special needs. Konkle, initially attacking the wrong person, later confronted Steele. During the fight, Steele, who had pre-existing heart conditions, was tackled by Konkle, who then hit Steele multiple times and compressed his chest. Steele subsequently died from mechanical asphyxiation complicated by his heart conditions.The Jackson Circuit Court charged Konkle with murder. During the trial, the State invoked the eggshell skull doctrine to argue that Konkle was responsible for Steele's death despite Steele's pre-existing conditions. The jury found Konkle guilty of voluntary manslaughter, and he was sentenced to thirty-four years in prison. Konkle appealed, arguing prosecutorial misconduct, insufficient evidence of a knowing killing, and an inappropriate sentence.The Indiana Court of Appeals reversed the conviction, citing prosecutorial misconduct due to the State's use of the eggshell skull doctrine and fundamental error. However, the Indiana Supreme Court granted transfer, vacating the appellate decision. The Supreme Court held that Konkle did not waive his prosecutorial misconduct claim and found no misconduct, as the eggshell skull doctrine was appropriately applied to causation, not mens rea. The court also found sufficient evidence to support the conviction, noting Konkle's actions and intent during the altercation. Finally, the court upheld the sentence, considering the nature of the offense and Konkle's character, including his criminal history and lack of remorse. The Indiana Supreme Court affirmed Konkle's conviction and sentence. View "Konkle v. State" on Justia Law

Antonio Turner, a student, was studying at a classmate's home when Dequan Briscoe, the classmate's jealous love interest, threatened to attack him. Turner, sensing danger, retrieved his handgun from his car. As he was returning to the house, an unfamiliar car sped towards him. Turner, unable to see inside the car due to its darkly tinted windows, fired four shots, wounding Briscoe, who was indeed aiming a gun at Turner.The Marion Superior Court, after a bench trial, convicted Turner of battery by means of a deadly weapon. The magistrate judge acknowledged that Turner’s actions were necessary to avoid being shot but found that it was objectively unreasonable for Turner to fire at a car he couldn’t see into, thus rejecting Turner’s self-defense claim.The Indiana Supreme Court reviewed the case and vacated Turner’s conviction. The court held that Indiana’s self-defense statute justifies the use of force when it is necessary for protection, even if the necessity is only fully apparent in hindsight. The court concluded that Turner’s shooting was justified because it was necessary to protect himself from an imminent threat, and the force used was proportional to the threat. The court emphasized that the self-defense statute does not require a person to be reasonable in their belief if the belief turns out to be correct. View "Turner v. State" on Justia Law

An Indiana trust beneficiary sued the trustee, an Indiana bank, in an Indiana trial court over the disposal of trust property. The trust, which holds Illinois real estate, is governed by Illinois law and includes mostly Illinois beneficiaries. The trial court dismissed the action for lack of subject-matter jurisdiction, questioning the appropriateness of resolving Illinois-centered issues in Indiana.The Vigo Superior Court dismissed the case, agreeing with the trustee that Indiana lacked subject-matter jurisdiction because the trust was administered in Illinois. The Indiana Court of Appeals reversed this decision, ruling that the trial court had jurisdiction over the Indiana suit despite the trust's Illinois connections. The appellate court distinguished this case from In re Alford Trust, which held that Indiana courts lack jurisdiction over trusts administered exclusively in another state.The Indiana Supreme Court reviewed the case and held that the trial court has subject-matter jurisdiction over the dispute. The court clarified that Indiana superior courts have broad civil jurisdiction, including over trust disputes, and that venue provisions do not affect jurisdiction. The court disapproved of the Alford Trust decision for conflating jurisdiction with prudential concerns like venue and choice of law. The court noted that while the trial court has jurisdiction, it may still dismiss the case under doctrines like comity or forum non conveniens if appropriate. The Indiana Supreme Court reversed the trial court's dismissal and remanded the case for further proceedings. View "Tingley v. First Financial Bank" on Justia Law

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

The plaintiffs, Hari and Saranya Nagireddy, live next to a property owned by Willow Haven on 106th Street, LLC, which is being developed to house up to ten residents with Alzheimer’s disease and dementia. After Willow Haven obtained a building permit from Carmel, the Nagireddys sued, seeking a declaration that the proposed use would be a public nuisance as it would violate Carmel’s unified development ordinance (UDO). They also obtained a preliminary injunction against further construction.The Hamilton Superior Court denied Willow Haven’s motion to dismiss and issued a preliminary injunction, finding that the Nagireddys did not need to exhaust administrative remedies before the Board of Zoning Appeals (BZA) and were likely to succeed on their claim. The Indiana Court of Appeals affirmed the trial court’s decision, with a majority holding that the Nagireddys were not required to exhaust administrative remedies and were likely to succeed on their nuisance claim. A dissenting judge argued that the UDO was ambiguous and should be interpreted to permit Willow Haven’s land use.The Indiana Supreme Court reviewed the case and held that the preliminary injunction was improper. The court found that the Nagireddys did not prove they were likely to win their public-nuisance claim, as they did not show that Willow Haven’s proposed land use violated the UDO at this preliminary stage. The court noted that the UDO incorporates state and federal law, which may protect Willow Haven’s land use. The court reversed the trial court’s decision, vacated the injunction, and remanded the case for further proceedings. View "Willow Haven on 106th St, LLC v. Nagireddy" on Justia Law

Gerard A. Kirsch, a member of Calvary Temple Church of Evansville, Inc., was injured while building a storage barn on the church's property. Kirsch fell from a ladder and sustained a severe arm injury. He sued the church, alleging negligence for failing to provide safe equipment and proper supervision.The Vanderburgh Superior Court denied the church's motion for summary judgment, which argued that Indiana Code section 34-31-7-2 limited the church's liability. The court held that a jury must decide if the church breached any duty to Kirsch. The Indiana Court of Appeals affirmed, interpreting the statute narrowly to apply only to parts of the premises used primarily for worship services, thus allowing Kirsch's claim to proceed.The Indiana Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that the term "premises" in Indiana Code section 34-31-7-2 includes the entire parcel of land owned by the church, not just the areas used primarily for worship services. Since the church's entire property is used primarily for worship services, the statute applies, limiting the church's liability to warning of hidden dangers and refraining from intentional harm. Kirsch admitted the church breached neither duty, leading the court to grant summary judgment in favor of the church. View "Calvary Temple Church of Evansville, Inc. v. Kirsch" on Justia Law

A motorist struck and injured a pedestrian during rush hour. The motorist claimed the pedestrian stepped out from behind a large truck, obstructing her view. Witnesses and investigating officers corroborated the motorist's account, finding no evidence of speeding, reckless driving, or distraction. The pedestrian sued the motorist and her insurer for negligence, and the motorist raised a contributory-negligence defense.The Hamilton Superior Court initially granted the pedestrian's motion to compel the motorist to produce her iPhone for inspection, limited to the hour surrounding the accident. However, the court reversed its decision upon reconsideration, citing significant privacy concerns and lack of evidence suggesting the motorist was using her phone at the time. The court also granted a motion in limine to exclude any discussion of the phone inspection at trial. A jury found the pedestrian 90% at fault, barring recovery under Indiana's contributory-fault standard. The Indiana Court of Appeals affirmed, holding that the burden of the proposed phone inspection outweighed its likely benefit given the motorist's privacy concerns.The Indiana Supreme Court affirmed the lower court's decision, holding that the pedestrian's discovery request lacked necessary evidentiary support and was overly broad. The court emphasized that privacy concerns are not a per se bar to discovery but must be balanced against the need for information. The court concluded that the trial court did not abuse its discretion in denying the motion to compel, as the pedestrian failed to show that the benefit of inspecting the motorist's phone outweighed her privacy interests. View "Jennings v. Smiley" on Justia Law