Justia Indiana Supreme Court Opinion Summaries

In 2015, American Acceptance Co. sued Timothy Mayberry in small claims court for an unpaid balance of $2,084.48. Mayberry did not respond, leading to a default judgment against him. In 2022, Mayberry, who is incarcerated, moved to set aside the default judgment, claiming he was never served with the complaint or judgment and only learned about it during a prison review. The small claims court denied his motion, deeming it untimely and meritless.Mayberry appealed the decision. However, the trial court clerk failed to file a Notice of Completion of Clerk’s Record by the required deadline, and Mayberry did not move to compel the clerk to file the notice. Consequently, the Indiana Court of Appeals dismissed the appeal sua sponte based on Appellate Rule 10(F), which states that failure to move to compel the clerk “shall subject the appeal to dismissal.” Mayberry’s subsequent motion to correct the error was denied by a divided motions panel.The Indiana Supreme Court reviewed the case and held that the phrase “shall subject the appeal to dismissal” grants appellate courts discretion to dismiss an appeal but does not mandate dismissal. The court emphasized that cases should be decided on their merits rather than minor procedural violations unless the appellant acts in bad faith, the violation is egregious, or the appellee is prejudiced. Finding no sufficient basis for dismissal under these criteria, the Indiana Supreme Court vacated the dismissal and remanded the case to the Court of Appeals for further proceedings. View "Mayberry v. American Acceptance Co LLC" on Justia Law

Russell Finnegan was held in indirect contempt by a judge for sending vulgar and offensive communications to the court. Finnegan's counsel requested a mental health evaluation under Indiana Code section 35-36-2-2(b), which the trial court denied. The Court of Appeals reversed this decision, finding the denial to be an error. The appellate court held that the statutory procedures for asserting an insanity defense in criminal proceedings should apply to indirect criminal contempt actions.The Pulaski Circuit Court initially found Finnegan in contempt for his communications, which included vulgar language and disrespectful remarks directed at the judge. During the contempt hearing, Finnegan's counsel mentioned that he was undergoing mental health evaluations in an unrelated criminal case and requested a continuance for these evaluations. The trial court denied the continuance and did not act on the request to appoint mental health experts. Finnegan was found in contempt and sentenced to 170 days in jail. The Court of Appeals reversed this decision, ruling that Finnegan was entitled to the same statutory protections as other criminal defendants, including the right to a mental health evaluation.The Indiana Supreme Court reviewed the case and vacated the Court of Appeals' opinion. The Supreme Court held that the statutory procedures for asserting an insanity defense in criminal cases do not apply to indirect criminal contempt actions because such actions are not considered "criminal cases" under the relevant statute. The court emphasized that indirect contempt is a sui generis proceeding, distinct from both criminal and civil cases. The court affirmed the trial court's decision, concluding that the insanity defense statutes do not apply to indirect contempt proceedings. View "Finnegan v. State" on Justia Law

Mathew Cramer was convicted of murdering and dismembering Shane Nguyen. Cramer, who lived in a storage unit, accepted a ride from Nguyen, and after a series of interactions, Cramer decided to kill Nguyen. He lured Nguyen to the storage unit, choked him, and then further assaulted him until he was dead. Cramer and an accomplice then dismembered Nguyen's body, placed the parts in trash bags, and attempted to dispose of them. They were apprehended after a police chase.The Allen Superior Court found Cramer guilty of murder, abuse of a corpse, and resisting law enforcement. The jury recommended a sentence of life imprisonment without parole (LWOP), which the trial court imposed. Cramer appealed, requesting a revision of his sentence to a term of years under Indiana Appellate Rule 7(B), arguing that his actions and character did not warrant LWOP.The Indiana Supreme Court reviewed the case and upheld the trial court's decision. The court found that the nature of Cramer’s offense was extremely brutal, involving premeditated murder and grotesque dismemberment of the victim. Additionally, Cramer’s criminal history and lack of mitigating factors supported the LWOP sentence. The court concluded that Cramer’s sentence was appropriate given the heinous nature of the crime and his character, and thus declined to revise it. View "Cramer v. State" on Justia Law

Cave Quarries, Inc. hired Warex LLC to conduct a controlled explosion to blast a rock wall at its quarry. The explosion went wrong, destroying Cave Quarries' asphalt plant. Cave Quarries sued Warex, claiming strict liability and negligence. The oral contract between the parties did not cover this scenario, so Cave Quarries turned to tort law.The Orange Circuit Court denied both parties' motions for summary judgment. The court held that strict liability did not apply because Cave Quarries was not an innocent bystander but a participant in the blasting. The court ruled that the negligence standard should apply and found material issues of fact precluding summary judgment. The Indiana Court of Appeals affirmed the trial court's decision, agreeing that the negligence standard should apply.The Indiana Supreme Court reviewed the case and affirmed the lower court's decision. The court held that strict liability for blasting does not extend to customers who hire the blaster, as they are participants in the activity and benefit from it. The court maintained that strict liability applies to damage caused to neighbors and bystanders but not to customers. The court remanded the case for further proceedings on the negligence claim, directing the trial court to enter judgment for Warex on the strict liability claim and proceed with the negligence claim. View "Cave Quarries Inc. v. Warex, LLC" on Justia Law

Four appellants sought post-conviction relief in Elkhart County, Indiana, alleging systemic police and prosecutorial misconduct that led to wrongful convictions. They argued that the judge, who had recused herself in a similar prior case involving Andrew Royer, should also recuse herself from their cases due to similar concerns about impartiality. The judge had previously recused herself in Royer's case because she had characterized Royer's attorney's comments as "defamatory" and had worked with many of the witnesses Royer intended to call, raising questions about her impartiality.In the lower courts, the Elkhart Circuit Court judge denied the appellants' motions for recusal, reasoning that her prior employment as a deputy prosecutor did not necessitate recusal and that her comments in Royer's case were misunderstood. The Indiana Court of Appeals affirmed the trial court's decisions, agreeing with the judge's reasoning.The Indiana Supreme Court reviewed the case and concluded that the judge's prior decision to recuse in Royer's case should have compelled her to recuse in these cases as well. The Court held that an objective observer, aware of the judge's prior recusal and the similar concerns raised in these cases, would reasonably question her impartiality. The Court emphasized that the judge's entanglement with the evidence had only deepened, and there was no change in circumstances that would eliminate the concerns leading to her initial recusal.The Indiana Supreme Court reversed the trial court's orders denying the motions for recusal and remanded the cases with instructions to grant the motions, ensuring that the judge recuses herself from these proceedings. View "Seabolt v. State" on Justia Law

Perdue Farms operates a poultry-processing plant in Indiana. In August 2018, an L&B Transport driver mistakenly delivered aluminum chloride instead of bleach, causing a chemical reaction that damaged the plant. Perdue sued L&B Transport, its driver, U.S. Security Associates, and three security guards employed by U.S. Security, seeking over $1.2 million in damages. The security-service contract between Perdue and U.S. Security included a forum-selection clause designating Maryland federal court as the venue for disputes.The Daviess Circuit Court dismissed Perdue’s claims against U.S. Security and its employees, citing the forum-selection clause. Perdue appealed, arguing the clause was unenforceable and did not apply to the employees. The Indiana Court of Appeals reversed, holding the clause unenforceable due to the potential for multiple lawsuits in different jurisdictions. A dissenting judge argued that Perdue, as a sophisticated entity, should adhere to its contractual agreement.The Indiana Supreme Court reviewed the case and held that the forum-selection clause is enforceable against U.S. Security, requiring Perdue to litigate those claims in Maryland federal court. However, the court found that the clause does not apply to the individual employees, as they were not parties to the contract and not in privity with U.S. Security. The court rejected the argument that the employees' duties under the contract made them subject to the forum-selection clause.The Indiana Supreme Court affirmed the trial court’s dismissal of claims against U.S. Security for improper venue but reversed the dismissal of claims against the individual employees. The case was remanded for further proceedings consistent with this opinion. View "Perdue Farms Inc. v. L & B Transport, LLC" on Justia Law

In June 2020, a fire broke out at a warehouse in Fort Wayne, Indiana. Richard Dolsen, a professional firefighter, responded to the scene. While navigating through the smoke-filled, dark warehouse, Dolsen fell through an unguarded opening above a basement stairwell, sustaining injuries to his neck and right arm. The warehouse was owned by Sweet Real Estate – City Center, LLC, and leased to VeoRide, Inc., which stored electric scooters and other equipment on the premises. Dolsen sued both companies, alleging negligence in failing to fix the wall opening and in failing to warn the fire department of the hazard.The trial court granted summary judgment in favor of VeoRide and Sweet, holding that Dolsen's claims were barred under the firefighter's rule, which limits a firefighter's ability to recover damages for injuries sustained while responding to a fire. Dolsen appealed the ruling only as to VeoRide, and the court of appeals reversed the trial court's decision, holding that the firefighter's rule did not bar Dolsen's claim against VeoRide.The Indiana Supreme Court granted VeoRide's petition to transfer the case. The court clarified that the firefighter's rule and the first-responder's rule are two separate doctrines. The firefighter's rule applies only to firefighters and prescribes the duty owed for a premises-liability claim arising when a firefighter enters premises to extinguish a fire. The first-responder's rule limits the duty owed to all first responders during an emergency.In this case, the court held that the first-responder's rule did not bar Dolsen's claim as he did not allege that the negligence that caused his injuries also caused the fire. As for the firefighter's rule, the court found that disputed factual issues remained on whether VeoRide breached its duty to Dolsen. Therefore, the court reversed the trial court's entry of summary judgment for VeoRide and remanded the case for further proceedings. View "Dolsen v. Veoride, Inc." on Justia Law

The case revolves around a dispute between Treslong Dairy, LLC, First Merchants Bank, the Earl Goodwine Trust, and Jeffrey and Kathie Foster. Treslong Dairy had executed promissory notes with all parties, granting them security interests in various properties. After Treslong defaulted on its note with the Bank, the Bank sued to collect its debt. The Trust and the Fosters (collectively “Farmers”) intervened in the action. When Treslong failed to sell its property, the Bank sought final judgment on its unpaid balance. The Bank sold the haylage and corn silage for $230,000, which was insufficient to satisfy the full judgment. As junior lienholders, the Farmers received no proceeds from the sale. The Farmers then sued the Bank for money damages, claiming that the sale was not conducted in a commercially reasonable manner.The trial court granted the Bank's motion to dismiss the Farmers' case under Rule 41(E), which allows for dismissal of a civil case for a party's failure to move the case along. The Farmers appealed, arguing that the Bank's motion was untimely for Rule 41(E) purposes. The Court of Appeals reversed the trial court's decision as to Rule 41(E) but affirmed based on laches.The Indiana Supreme Court agreed with the Farmers. It held that the Bank's motion for dismissal under Rule 41(E) was untimely because it was filed after the Farmers had resumed prosecution by requesting a case-management conference. Therefore, the case could not be dismissed under that rule. The court also rejected the Bank's alternative argument that the equitable doctrine of laches applied. The court reversed the lower court's dismissal order and remanded for proceedings consistent with its opinion. View "Foster v. First Merchants Bank, N.A." on Justia Law

In June 2021, Cohen Hancz-Barron was living with his on-and-off girlfriend, Sarah Zent, and her three young children in Fort Wayne, Indiana. On the morning of June 2, Hancz-Barron drove away in a neighbor's truck, and Sarah and her children were later found dead in their home. The victims had been stabbed multiple times, with wounds severing their jugular veins and carotid arteries. Hancz-Barron quickly became the primary suspect, and he was arrested later that day in Lafayette, Indiana. The State charged Hancz-Barron with four counts of murder and sought a sentence of life without the possibility of parole.At trial, the State presented photographic, DNA, video, and physical evidence, as well as testimony from family members, friends, law enforcement, a forensic pathologist, and a forensic biologist. The jury found Hancz-Barron guilty as charged. At sentencing, the State incorporated the evidence presented during the guilt phase to support the two statutory aggravators. The defense presented mitigating evidence through testimony from both Hancz-Barron’s mother and a forensic psychologist who examined Hancz-Barron after his arrest. The jury found the State proved both statutory aggravators beyond a reasonable doubt, found the aggravating circumstances outweighed the mitigating circumstances, and recommended “a sentence of life imprisonment without parole.” The trial court then found “more than sufficient evidence to support” the jury’s decision, and sentenced Hancz-Barron to four consecutive life sentences.In the Indiana Supreme Court, Hancz-Barron challenged the sufficiency of evidence to sustain his convictions, the trial court’s decision allowing the State to recall a witness, and his sentence on both statutory and constitutional grounds. The court rejected each challenge and affirmed the lower court's decision. The court held that sufficient evidence supported Hancz-Barron’s convictions and that the trial court did not abuse its discretion in allowing the State to recall a witness. The court also held that it could not review the jury’s weighing of aggravating and mitigating circumstances, Hancz-Barron had not shown that his sentence was inappropriate, and his sentence was not unconstitutional. View "Hancz-Barron v. State" on Justia Law

The defendant, William R. Grimes, was charged with multiple crimes following a violent altercation with Matthew Pirtle. Grimes requested a speedy trial under Criminal Rule 4, which was granted by the court. However, due to a series of events including the addition of new charges, a conflict of interest with the trial judge, and court congestion, the trial was postponed beyond the 70-day limit stipulated by Rule 4. Grimes objected to this delay and filed a motion for discharge, arguing that the court's claim of congestion was inaccurate. His motion was denied without explanation by the trial court.The case was initially heard in the Sullivan Superior Court, where Grimes' motion for discharge was denied. Grimes appealed this decision to the Indiana Court of Appeals, which affirmed the lower court's ruling. The appellate panel held that Grimes failed to show he was entitled to discharge because he presented no evidence that the trial court’s congestion finding was clearly erroneous on the date it continued the trial.The case was then reviewed by the Indiana Supreme Court. The court held that Grimes had met his burden to show a prima facie case of no court congestion when he submitted the court’s docket showing no other scheduling conflicts with priority over his criminal trial. This shifted the burden to the trial court to explain the postponement. However, the trial court failed to meet this burden as it gave no explanation when it denied the defendant’s motion for discharge. As a result, the Indiana Supreme Court reversed the lower courts' decisions and remanded the case with instructions to discharge Grimes. View "Grimes v. State of Indiana" on Justia Law