Justia Indiana Supreme Court Opinion Summaries

Kimberly Anderson was charged with three felonies after stabbing her boyfriend with a boxcutter and threatening to kill him. Before trial, she entered a plea agreement with the State, pleading guilty to two charges—felony domestic battery and felony intimidation. In exchange, the State dropped one charge, refrained from adding another, and agreed to a maximum executed sentence of four years, with the specific sentence left to the trial court’s discretion. The agreement included a provision in which Anderson waived her right to appeal any sentence imposed within the terms of the agreement.At the sentencing hearing in the Marion County Superior Court, the judge reviewed the plea agreement with Anderson, confirmed her understanding, and heard arguments from both sides regarding aggravating and mitigating factors. The court ultimately sentenced Anderson to three years executed and three years suspended to probation. After sentencing, the court mistakenly told Anderson she could appeal her sentence, prompting her to do so. Anderson’s appeal to the Indiana Court of Appeals argued that the trial court abused its discretion by considering improper factors and failing to recognize significant mitigating evidence. The State moved to dismiss the appeal based on the waiver, and a divided motions panel of the Court of Appeals dismissed the appeal. Anderson then sought transfer to the Indiana Supreme Court.The Indiana Supreme Court held that a sentence is “illegal”—and thus not subject to an appeal waiver—only if it is outside the statutory range or unconstitutional. Anderson’s sentence was within the statutory range and not unconstitutional; her arguments concerned alleged abuse of discretion, not illegality. The Court found the appeal waiver valid and comprehensive, and dismissed Anderson’s appeal. View "Kimberly R. Anderson v. State of Indiana" on Justia Law

Bedford Recycling, Inc. applied to the Monroe County Board of Zoning Appeals (BZA) for a conditional use permit to operate a scrap metal collection and sorting facility on property zoned for mineral extraction. The county’s zoning ordinance did not specifically allow scrap metal recycling, so Bedford sought approval under the category of “Central Garbage/Rubbish Collection Facility.” The BZA granted the permit after a public hearing in which Bedford acknowledged the facility would not handle solid waste, a typical requirement for the permit. Subsequently, Republic Services, a neighboring property owner, filed for judicial review, arguing that Bedford’s facility did not meet the ordinance’s requirements. While preparing written findings to support its decision, the BZA’s attorney concluded that granting the permit was a legal error, as Bedford’s proposed use did not fit the permit’s definition.After several meetings and changes in BZA membership, the Board voted to revoke Bedford’s permit, finding that the facility was essentially a scrap yard, which was not a permitted use in the zoning district. Bedford then sought judicial review in the Monroe Circuit Court, which found that the BZA lacked statutory authority to revoke the permit based on a change in reasoning or alleged legal error, and reinstated the permit. The Indiana Court of Appeals reversed, holding that the BZA could correct its own legal error and revoke the permit.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Court held that administrative bodies like the BZA have only the powers expressly granted by statute and possess no inherent or common law authority to reconsider or revoke final decisions absent explicit legislative authorization. The Court disapproved prior appellate decisions that recognized an “error of law” exception. Accordingly, the Supreme Court affirmed the trial court’s order vacating the BZA’s revocation and reinstated Bedford’s conditional use permit. View "Monroe County Board of Zoning Appeals v. Bedford Recycling, Inc." on Justia Law

A commercial real estate broker and consultant partnered with three brothers who owned an architecture and construction company to develop and lease a commercial property. They planned to form a limited liability company (LLC) as equal members, contributing professional services and cash, but did not formalize their agreement in writing. After a dispute arose over a broker commission, the brothers executed a backdated operating agreement that excluded the broker from LLC membership. The broker alleged he was unfairly cut out of the deal and sued for breach of contract and unjust enrichment.The Marshall Circuit Court granted summary judgment to the brothers on the contract claim, finding that Indiana law required written confirmation for LLC membership, which the broker lacked. The court also denied the broker’s request for a jury trial on the unjust enrichment claim, holding that both the claim and the defense of unclean hands were equitable issues for the judge. After a bench trial, the court ruled against the broker on unjust enrichment, finding he failed to prove his claim and that unclean hands barred recovery.On appeal, the Indiana Court of Appeals reversed, holding that initial LLC membership could be established by oral agreement and that unjust enrichment claims for money damages were legal claims entitled to a jury trial. The Indiana Supreme Court granted transfer, vacating the appellate decision.The Indiana Supreme Court held that LLC membership under the Business Flexibility Act requires either a written operating agreement or written confirmation, and the broker was not a member as a matter of law. However, genuine factual disputes remained regarding whether the brothers breached an agreement to make him a member, precluding summary judgment. The Court also held that unjust enrichment claims for money damages are legal claims subject to a jury trial, and the unclean hands doctrine may be asserted as a defense. The judgment was vacated and the case remanded for a jury trial on both claims. View "Andrew Nemeth Properties, LLC v. Panzica" on Justia Law

A serious automobile accident occurred in June 2018 involving Tommi Hummel, who was insured by Standard Fire Insurance Company. The accident resulted in severe injuries to Bradley Baldwin and John Hopkins, both of whom were involved in the crash, while a third passenger, Jill McCarty, left the scene. Hummel’s insurance policy provided $50,000 per person and $100,000 per accident in bodily injury liability coverage. After the accident, Baldwin sued the Hummels for negligence and made a time-limited settlement demand for the $50,000 per-person policy limit. Standard Fire, recognizing that multiple claims could exceed the policy limits, rejected Baldwin’s demand and instead filed an interpleader action, depositing the $100,000 policy limit with the trial court and naming all potential claimants.The Marshall County Circuit Court granted summary judgment for Standard Fire, finding that it had not breached any duty to its insureds and was released from further liability. The Indiana Court of Appeals affirmed in part but reversed on the issues of breach of the duty of good faith and bad faith, holding that genuine issues of material fact existed regarding Standard Fire’s rejection of Baldwin’s settlement demand and its conduct in filing the interpleader action.The Indiana Supreme Court reviewed the case and affirmed the trial court’s grant of summary judgment for Standard Fire. The Court adopted Section 26 of the Second Restatement of Liability Insurance, establishing that an insurer facing multiple claims against insufficient policy limits fulfills its duty of good faith by filing an interpleader action, naming all known claimants, depositing policy limits with the court, and continuing to defend the insured. The Court held that Standard Fire’s actions satisfied this standard and did not constitute a breach of the duty of good faith or bad faith. View "Baldwin v. The Standard Fire Insurance Co." on Justia Law

An unwed couple had a child in July 2013. The father’s name was not listed on the birth certificate, and he died about a year and a half later. The child’s paternal grandmother remained involved in the child’s life and provided support to the mother. In 2018, the grandmother petitioned for visitation and to establish the father’s paternity, submitting a DNA report indicating a high likelihood of paternity. After a hearing, the mother and grandmother, both represented by counsel, submitted an agreed order to the Porter Superior Court. The mother agreed to change the child’s surname, add the father’s name to the birth certificate, and acknowledged in open court that the father was the child’s father. The trial court approved the agreed order.Subsequent disputes arose regarding visitation, leading to contempt motions and further hearings. The trial court maintained the agreed order, found the mother in contempt, and later appointed a guardian ad litem following additional petitions. At a final hearing, the guardian ad litem recommended joint legal custody with the grandmother as primary custodian. The trial court requested briefing, after which the grandmother filed her brief and the mother moved to dismiss the visitation petition, arguing the grandmother lacked standing under the Grandparent Visitation Act (GVA). The trial court denied the mother’s motion, finding she had waived any challenge to standing by stipulating to the agreed order. The Indiana Court of Appeals reversed, holding the grandmother lacked standing because paternity had not been formally established.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Supreme Court held that the mother was equitably estopped from denying the father’s paternity due to her prior stipulations and conduct. Therefore, the grandmother had standing under the GVA to petition for visitation. The Supreme Court affirmed the trial court’s judgment. View "O'Connell v. Clay" on Justia Law

The petitioners own a home on nearly four acres of land in a gated community in Crown Point, Indiana. For the 2019 tax year, the Lake County Assessor classified one acre of their property as a “homestead” and taxed it at one percent of its assessed value, while the remaining 2.981 acres were taxed as non-residential property at a higher rate. The owners did not dispute the total assessed value but argued that the statutory one-acre limit for the homestead tax cap was unconstitutional as applied to them, claiming that their entire parcel constituted “curtilage” under the Indiana Constitution and should be subject to the lower tax rate.After the Lake County Property Tax Assessment Board of Appeals rejected their claim, the Indiana Board of Tax Review affirmed, stating it lacked authority to declare a statute unconstitutional and was bound by the one-acre limit. The petitioners appealed to the Indiana Tax Court, which reversed the Board’s decision. The Tax Court held that the Constitution does not permit a fixed one-acre limitation for the homestead tax cap and remanded for further proceedings to determine whether the excess acreage was used as part of the principal place of residence.The Indiana Supreme Court reviewed the Tax Court’s decision de novo. It held that, even if the Constitution does not impose a size limit on curtilage, the petitioners failed to present sufficient evidence that their excess land was used as curtilage. Therefore, they did not meet their burden to prove the statute unconstitutional as applied to them. The Supreme Court reversed the Tax Court’s judgment and remanded with instructions to affirm the Board’s determination in favor of the Assessor. View "Sawlani v. Lake County Assessor" on Justia Law

A 63-year-old man with a history of sciatica and alcohol-use disorder attempted to board a city bus in Indianapolis. Earlier that day, he had been hospitalized for intoxication but was released while still mildly intoxicated. That evening, after waiting at a bus stop, he approached a bus as it was preparing to leave. As the bus pulled away, he lost his balance and fell into the road, where he was run over and later died from his injuries. At the time of the incident, his blood-alcohol content was approximately 0.261. His mother, acting as the personal representative of his estate, filed a wrongful death suit against the public transportation corporation, alleging negligence.The Marion Superior Court presided over a jury trial in which the transportation corporation argued that the decedent was contributorily negligent, which would bar recovery. The jury viewed video footage of the incident and heard testimony regarding the decedent’s physical condition and intoxication. After deliberation, the jury found in favor of the estate and awarded damages, later reduced by statutory limits. The transportation corporation moved for judgment on the evidence and, after the verdict, for a motion to correct error, both of which the trial court denied. On appeal, the Indiana Court of Appeals reversed, finding the decedent contributorily negligent as a matter of law.The Indiana Supreme Court granted transfer, vacated the Court of Appeals’ opinion, and reviewed the trial court’s denial of the motion to correct error de novo. The Court held that the evidence, including the video footage and testimony, did not establish as a matter of law that the decedent was contributorily negligent. Multiple reasonable inferences could be drawn from the evidence, so the jury’s verdict was not clearly erroneous or unsupported. The Supreme Court affirmed the trial court’s denial of the motion to correct error. View "Indianapolis Public Transportation Corporation v. Bush" on Justia Law

A juvenile, D.W., was charged with child molestation and dissemination of material harmful to minors. During the initial hearing, the juvenile court allowed D.W.'s counsel to waive a formal advisement of rights without personally confirming with D.W. if he agreed to the waiver. After a fact-finding hearing, D.W. was adjudicated delinquent. D.W. appealed, arguing that the juvenile court erred by not providing a formal advisement of rights and that his counsel's waiver was invalid because it was not confirmed that D.W. knowingly and voluntarily joined the waiver.The Marion Superior Court adjudicated D.W. delinquent, and the Indiana Court of Appeals affirmed the decision. The Court of Appeals found that the delinquency petition provided sufficient notice of the charges and that any errors in the advisement of rights did not rise to the level of fundamental error. The court also noted that D.W. exercised his constitutional rights during the proceedings.The Indiana Supreme Court reviewed the case and agreed that the juvenile court erred by not providing a formal advisement of rights and that the waiver by D.W.'s counsel was invalid because the court did not personally confirm the waiver with D.W. However, the Supreme Court found the error to be harmless because D.W.'s substantial rights were not affected. D.W. was represented by counsel, exercised his constitutional rights, and there was no indication that the lack of formal advisement impacted the outcome of the case. Therefore, the Indiana Supreme Court affirmed the juvenile court's delinquency adjudication. View "D.W. v. State" on Justia Law

Keith Huck, an elected member of the Perry County Common Council, was covered under the county's group health insurance plan. In 2023, the Perry County Board of Commissioners voted to exclude part-time employees from health insurance coverage, classifying elected officials, including Huck, as part-time employees. As a result, Huck and his spouse lost their health insurance coverage on January 1, 2024. Huck sought declaratory and injunctive relief, arguing that as an elected official, he should be considered a full-time employee and thus eligible for health insurance coverage.The Perry Circuit Court granted Huck's request for a preliminary injunction, ordering the county to reinstate his insurance coverage. The County appealed, and the Indiana Court of Appeals determined that the county had the authority to classify elected officials as part-time employees and exclude them from health insurance coverage. Huck then sought transfer to the Indiana Supreme Court, which vacated the appellate opinion and reviewed the case.The Indiana Supreme Court held that the county was within its rights to classify Huck as a part-time employee and exclude him from group health insurance coverage. The court found that Indiana law allows local governmental units to exclude part-time employees from group health insurance and that the county's classification of Huck as a part-time employee was permissible. The court reversed the trial court's ruling, vacated the preliminary injunction, and remanded the case for further proceedings consistent with its opinion. View "Perry County v. Huck" on Justia Law

M.C. arrived at the Sandra Eskenazi Mental Health Center exhibiting manic behavior. The center sought and obtained an emergency involuntary detention. Subsequently, they petitioned for a temporary commitment. During the hearing, Dr. Jayme Ahmed testified that M.C. had a prior schizophrenia diagnosis, exhibited delusional behavior, and refused medication. M.C. believed he needed to go to Washington, D.C., to broadcast a "state of emergency" and planned to call his father for bus fare. He also reported that his social security benefits had stopped. Dr. Ahmed expressed concern that M.C.'s fixation on Washington, D.C., and lack of stable income would impair his ability to provide for himself.The Marion Superior Court ordered M.C.'s temporary commitment, finding him gravely disabled. M.C. appealed, arguing insufficient evidence of his grave disability and that his case was not moot. The Indiana Court of Appeals dismissed the appeal as moot, stating M.C. failed to demonstrate particularized collateral consequences of his commitment.The Indiana Supreme Court reviewed the case, noting that their recent decision in J.F. v. St. Vincent Hosp. and Health Care Ctr., Inc. established that appeals of temporary commitment orders are not moot unless the appellee shows no collateral consequences. The Court found the Court of Appeals' decision conflicted with J.F. by declaring the appeal moot and improperly placing the burden on M.C. to show collateral consequences. The Indiana Supreme Court vacated the Court of Appeals' decision and affirmed the trial court's temporary commitment order, concluding that sufficient evidence supported M.C.'s commitment. View "In re Commitment of M.C." on Justia Law