Justia Indiana Supreme Court Opinion Summaries

Bernadette O’Malley purchased a used 2007 Dodge Caliber from Valpo Motors, Inc. in late 2019. Valpo provided O’Malley with a Buyers Guide stating the car was sold “AS IS” and a Sales Agreement that disclaimed all warranties unless a written warranty or service contract was extended within 90 days. O’Malley also purchased a Service Contract, which was noted in the Buyers Guide. The car broke down a month later, and a repair shop deemed it not worth repairing due to extensive mechanical issues. O’Malley’s son-in-law, Glenn Thomas, took the car to the shop. After Valpo refused to arbitrate, O’Malley sued for breach of implied warranty of merchantability under the Magnuson-Moss Warranty Act (MMWA). O’Malley passed away during the proceedings, and Thomas continued the case as the personal representative of her estate.The Porter Superior Court granted summary judgment for Valpo Motors, and the Indiana Court of Appeals affirmed, holding that the Buyers Guide’s disclaimer of all warranties controlled over any contrary provisions in the Sales Agreement. The appellate court rejected Thomas’s argument that the handwritten note on the Buyers Guide negated the warranty disclaimer. Judge Felix dissented, arguing that the Sales Agreement’s specific terms should trump the Buyers Guide’s general terms and that there was a genuine issue of material fact regarding Valpo’s opportunity to cure the breach.The Indiana Supreme Court reviewed the case and held that Valpo did not effectively disclaim the implied warranty of merchantability due to ambiguities in the Buyers Guide. The court found that fact issues remained regarding whether Valpo had a reasonable opportunity to cure the defects. The court vacated the summary judgment for Valpo, directed the trial court to enter partial summary judgment for Thomas on the warranty-disclaimer issue, and remanded for further proceedings to determine if Valpo had a reasonable opportunity to cure. If Thomas prevails, the trial court is to assess damages and reasonable attorney’s fees. View "Thomas v. Valpo Motors Inc." on Justia Law

In January 2023, J.F., a 39-year-old woman with a history of substance abuse, began experiencing severe delusions and paranoia, believing her parents wanted to kill her and her children. After a series of incidents, including living in her car and being admitted to the St. Vincent Stress Center, J.F. was temporarily committed by a trial court for up to ninety days due to her mental illness and inability to keep herself safe.J.F. appealed the commitment, arguing insufficient evidence supported the order. The Court of Appeals dismissed her appeal as moot, stating it did not present a novel issue or particularized harmful consequence. J.F. then petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court held that temporary commitment appeals are not moot upon expiration unless the appellee proves no collateral consequences exist. The court emphasized the significant liberty interests and lifelong collateral consequences involved in such commitments, warranting appellate review. The court found sufficient evidence to support J.F.'s commitment, noting her impaired reasoning, inability to function independently, and the danger she posed to herself. Consequently, the court affirmed the trial court's temporary commitment order. View "In re Commitment of J.F." on Justia Law

McKinley Kelly, at sixteen, was convicted of murdering three young adults. The trial court vacated one conviction and sentenced him to 110 years in prison. Kelly's appeals and petitions for post-conviction relief were unsuccessful. The Court of Appeals allowed him to file a successive petition for post-conviction relief, focusing on new scientific understandings of adolescent brain development, arguing for a resentencing or a more lenient sentence.The Lake Superior Court denied Kelly's petition, and the Court of Appeals affirmed. Kelly then appealed to the Indiana Supreme Court, which granted transfer to address procedural and substantive issues related to juvenile sentencing. The Indiana Supreme Court affirmed the post-conviction court's decision, concluding that the post-conviction court appropriately allowed Kelly to amend his successive petition without requiring appellate screening.The Indiana Supreme Court held that the state and federal constitutional provisions cited by Kelly did not mandate a more lenient sentence. The court found that Kelly's sentence was not inappropriate given the nature of his offenses and his character. The court emphasized that the legislature had recently amended the sentence modification statute to allow juvenile offenders to have their sentences reexamined after twenty years, providing an opportunity for review based on rehabilitative progress.The court concluded that Kelly's new evidence on adolescent brain development was cumulative and unlikely to produce a different result. The court also rejected Kelly's claims under the Indiana Constitution, finding that his sentence did not violate provisions related to cruel and unusual punishment, proportionality, reformation, unnecessary rigor, or equal protection. Similarly, the court found no violation of the Eighth or Fourteenth Amendments of the U.S. Constitution. Finally, the court declined to revise Kelly's sentence under Appellate Rule 7(B), finding it appropriate in light of the nature of his offenses and his character. View "Kelly v. State of Indiana" on Justia Law

Diamond Quality, Inc., an industrial inspection and sorting company, had been working with subsidiaries of Dana Incorporated, including Dana Light Axle Products, LLC (Dana Fort Wayne). In 2019, Dana Fort Wayne stopped using Diamond's services. In 2020, Dana Fort Wayne twice refused Diamond entry onto its premises to sort defective parts, despite requests from other Dana subsidiaries in Mexico.Diamond sued Dana Fort Wayne in Allen County state court, alleging tortious interference with its business relationships and contracts with the Dana subsidiaries in Mexico. Dana Fort Wayne removed the case to the United States District Court for the Northern District of Indiana, where it denied the allegations and moved for summary judgment, arguing that barring Diamond from its premises was not tortious.The district court sought guidance from the Indiana Supreme Court on whether a corporate subsidiary can tortiously interfere with the contracts and business relationships of another subsidiary of the same parent company. The Indiana Supreme Court reframed the question to whether a property owner acts without justification, for purposes of a claim for tortious interference, when barring a plaintiff from accessing the property.The Indiana Supreme Court held that a property owner is always justified in excluding another from its premises absent a contractual or statutory duty. This right to exclude is fundamental to property law and cannot support a claim for tortious interference under Indiana law. The court did not need to choose between the second and third restatements of torts for this decision. The answer to the reframed certified question was "no." View "Diamond Quality, Inc. v. Dana Light Axle Products, LLC" on Justia Law

Robert Saint, an attorney representing a whistleblower in a False Claims Act case, requested a legal memorandum (White Paper) from the Family & Social Services Administration (FSSA) under Indiana’s Access to Public Records Act (APRA). The White Paper was created by HealthNet, a private entity, and given to FSSA for use during Medicaid settlement negotiations. FSSA denied the request, claiming the document was protected by attorney-client privilege and the deliberative material exception.The Marion Superior Court ordered FSSA to disclose the White Paper, finding that FSSA failed to demonstrate an attorney-client relationship or that the document was deliberative material prepared for FSSA’s decision-making. The court also found that any privilege was waived when the document was tendered to FSSA. FSSA appealed, reasserting the deliberative material exception and arguing that the document was used for decision-making within the agency.The Indiana Court of Appeals affirmed the trial court’s decision, rejecting FSSA’s arguments and finding that the White Paper was neither intra-agency nor interagency material. The court also found that FSSA waived its private contractor and confidentiality arguments by not raising them earlier.The Indiana Supreme Court reviewed the case and affirmed the trial court’s order. The court held that the deliberative material exception did not apply because the White Paper was not intra-agency material. The court emphasized that intra-agency material must originate from and be communicated between employees of the same agency. Since the White Paper was created by HealthNet and not generated within FSSA, it did not qualify for the exception. The court concluded that FSSA failed to meet its burden of proof and ordered the disclosure of the White Paper. View "Family & Social Services Administration v. Saint" on Justia Law

Chelsea L. Crossland was convicted by a jury of murder and neglect of a dependent resulting in death, specifically her five-year-old son, Christian Crossland. Christian was subjected to severe neglect and abuse after moving in with his mother in January 2022. He was confined to a bedroom closet, deprived of food, and beaten. On the night of his death, Christian was found emaciated and injured. Crossland delayed calling for help and provided conflicting accounts of the events leading to his death. An autopsy revealed that Christian died from blunt-force injuries, starvation, and dehydration.The Jay Circuit Court denied Crossland's motion for a change of venue due to pretrial publicity and her motion to strike several jurors for cause. The jury found Crossland guilty, and the trial court imposed a life-without-parole (LWOP) sentence based on the jury's recommendation. Crossland appealed directly to the Indiana Supreme Court, arguing that she was denied an impartial jury and the right to present a complete defense.The Indiana Supreme Court reviewed the case and found no evidence that the jury was unable to render an impartial verdict despite pretrial publicity. The court also determined that the trial court did not abuse its discretion in denying Crossland's motion for a change of venue or in its handling of juror challenges. Additionally, the court held that the exclusion of certain impeachment evidence did not violate Crossland's constitutional rights and that any error in excluding this evidence was harmless given the overwhelming evidence of her guilt.The Indiana Supreme Court affirmed the trial court's judgment, upholding Crossland's conviction and LWOP sentence. View "Crossland v. State" on Justia Law

In April 2018, Kiera Isgrig, a college student, was injured when a window and its casing fell on her while she was studying in a room at Indiana University. There was no direct evidence explaining why the window fell. Kevin Ashley, a university carpenter, found no defects that would have caused the window to fall without warning, although two sash springs were broken. The window had been last serviced in March 2017.The Monroe Circuit Court granted summary judgment in favor of the Trustees of Indiana University, finding that Isgrig failed to make a prima facie case of negligence under the premises liability standard. The court held that the university did not have actual or constructive knowledge of any issues with the window and that the doctrine of res ipsa loquitur did not apply.The Indiana Court of Appeals reversed and remanded, finding that the doctrine of res ipsa loquitur could apply to fixtures in premises liability cases. The court determined that a window falling out of a wall without interaction is not an event that typically occurs absent negligence and that there was sufficient evidence that the university had exclusive control over the window.The Indiana Supreme Court reviewed the case and held that the doctrine of res ipsa loquitur can be applied to premises liability cases involving fixtures. The court found that Isgrig presented sufficient evidence to create a genuine issue of material fact regarding the university's negligence. The court concluded that the window was under the exclusive control of the university and that such an incident would not normally occur without negligence. The court reversed the summary judgment and remanded the case for further proceedings. View "Isgrig v. Trustees of Indiana University" on Justia Law

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