Justia Indiana Supreme Court Opinion Summaries

Grandparents, J.D. and M.D., petitioned to adopt their great-grandchild, P.J.W., who has lived with them for most of his life due to his parents' struggles with incarceration, substance abuse, and violence. They successfully obtained guardianship over the child in 2020. The child's biological father, R.W., contested the adoption, arguing that he had rehabilitated and wanted to maintain his parental rights. Despite the Grandparents' stable and supportive environment, the trial court denied the adoption petition, citing their advanced ages and the father's purported rehabilitation.The Montgomery Superior Court concluded that adoption was not in the child's best interest, emphasizing the Grandparents' ages and the father's progress in rehabilitation. The court also held that it is inherently in a child's best interest to be raised by a biological parent. The Grandparents appealed this decision.The Indiana Court of Appeals affirmed the trial court's decision in a 2-1 opinion, deferring to the trial court's judgment under the applicable standard of review. However, Judge Crone dissented, arguing that the trial court's legal conclusion about the inherent best interest of being raised by a biological parent was improper and that the Grandparents had demonstrated their capability to provide a stable and supportive environment for the child.The Indiana Supreme Court reviewed the case and held that the trial court erred by not considering the Grandparents' ages in light of their ability to rear and support the child under Indiana Code subsection 31-19-11-1(a)(2). The Supreme Court also found that the trial court's conclusion that it is inherently in a child's best interest to be raised by a biological parent was an erroneous legal conclusion. The Supreme Court reversed the trial court's decision and remanded the case with instructions to reconsider the Grandparents' ages in light of their ability to raise the child and to conduct a new best-interest determination using the proper legal standard. View "J. D. v. R. W." on Justia Law

In late 2019, a hospital sent letters to over a thousand patients, including Linda Gierek, informing them of potential exposure to infectious diseases due to a technician's failure to fully sterilize surgical instruments. Gierek filed a class-action complaint against the hospital, asserting claims of negligent infliction of emotional distress, negligence, and medical malpractice. She sought class certification for similarly situated patients and their spouses. The trial court consolidated Gierek’s action with a similar class-action claim filed by Cheyanne Bennett.The Indiana Patient’s Compensation Fund intervened, arguing that the claims sounded in ordinary negligence and thus the Medical Malpractice Act (MMA) did not apply. The hospital argued the opposite. The trial court ruled in favor of the hospital, stating the MMA applied, and denied the motion for class certification, citing lack of subject-matter jurisdiction while a proposed complaint was pending before a medical-review panel. On appeal, the Court of Appeals affirmed the MMA’s applicability but reversed the trial court’s decision on class certification jurisdiction.The Indiana Supreme Court reviewed the case and held that the MMA covers all claims for medical malpractice, not limited to bodily injury or death. The court also held that class certification is a proper preliminary determination under the MMA. The court affirmed in part, reversed in part, and remanded the case for the trial court to consider the plaintiffs’ motion for class certification. View "Gierek v. Anonymous 1" on Justia Law

A physician sexually assaulted a twelve-year-old boy during a medical examination that required touching the child's genitals. The child's parents filed a medical malpractice complaint, including a negligent-credentialing claim against the hospital employing the physician. After settling with the hospital, the family sought excess compensation from the Indiana Patient’s Compensation Fund. The defendants moved for summary judgment, arguing that neither the sexual assault nor the hospital’s negligence fell within the Medical Malpractice Act (MMA). The trial court denied the motion.The Indiana Court of Appeals reversed the trial court's decision, granting summary judgment to the defendants. The appellate court held that the defendants could challenge the MMA’s applicability post-settlement, that a negligent-credentialing claim must be based on an underlying act of medical malpractice, and that the physician’s sexual misconduct did not constitute medical malpractice. One judge dissented, arguing that the negligent-credentialing claim need not rest on underlying medical malpractice and that the physician’s misconduct did constitute malpractice.The Indiana Supreme Court reviewed the case and affirmed the trial court's denial of summary judgment. The court held that the Fund could challenge whether a claim falls within the MMA after a settlement. It also held that a negligent-credentialing claim falls within the MMA only if the credentialed physician commits an act of medical malpractice. Finally, the court concluded that claims based on sexual assault by a physician during an authorized medical examination can fall within the MMA if the misconduct stems from an inseparable part of the health care being rendered. The court found that the physician’s sexual misconduct in this case fit within this narrow category, and thus, the defendants were not entitled to judgment as a matter of law. View "Department of Insurance v. Doe" on Justia Law

The case involves the regulatory approval of Duke Energy Indiana, LLC's proposed infrastructure improvements under the TDSIC statute, which allows utilities to recoup costs of approved improvements as they are completed. The Indiana Utility Regulatory Commission approved Duke's TDSIC plan, finding it reasonable. The key issue on appeal was the interpretation of the statute's cost-justification section: whether each improvement must be cost-justified individually or whether all improvements combined must be cost-justified.The Indiana Utility Regulatory Commission approved Duke's plan, interpreting the statute to mean that the overall plan must be cost-justified. The Indiana Court of Appeals affirmed this decision, applying a deferential standard of review to the Commission's interpretation. The appellants, including the Indiana Office of Utility Consumer Counselor and other groups, argued that the statute requires each individual improvement to be cost-justified.The Indiana Supreme Court reviewed the case and held that the scope of the Commission's authority to approve a TDSIC plan is a question of law, requiring plenary review rather than deference to the Commission's interpretation. The Court concluded that the Commission must determine whether each individual improvement within a TDSIC plan is cost-justified. However, the Court found that the Commission had made the required determination in this case, as it considered the benefits of individual projects, including those with a benefit-to-cost ratio below 1.0, and concluded that the overall plan was reasonable. Therefore, the Indiana Supreme Court affirmed the Commission's order approving Duke's TDSIC plan. View "Office of Utility Consumer Counselor v. Duke Energy Indiana, LLC" on Justia Law

Stevie Bradley was accused of multiple felonies, including attempted murder and domestic battery, after a violent incident with his girlfriend, A.R. Bradley demanded A.R. call another man, and when no one answered, he assaulted her. The violence continued as he drove through rural St. Joseph County, eventually threatening her with a machete. A.R. fled to a nearby home, but Bradley recaptured her, further assaulting her before she managed to escape again. The State charged Bradley with several offenses, and he requested a speedy trial.The St. Joseph Superior Court initially set Bradley's trial within the seventy-day window required by Criminal Rule 4(B). However, the court later ordered a competency evaluation for Bradley, vacating the original trial date. After Bradley was deemed competent, the court reset the trial date beyond the seventy-day period, leading Bradley to file multiple motions for discharge, arguing that his right to a speedy trial was violated. The trial court denied these motions, and Bradley was convicted on all charges except strangulation.The Indiana Court of Appeals vacated Bradley's convictions, ruling that the trial court erred by resetting the seventy-day period instead of merely tolling it during the competency evaluation. The court found no justification for scheduling the trial beyond the original deadline. The State petitioned for transfer, which the Indiana Supreme Court granted.The Indiana Supreme Court held that a trial court’s sua sponte order for a competency evaluation does not reset the Criminal Rule 4(B) period but merely tolls it. However, the court also held that Bradley waived his right to discharge by failing to properly notify the trial court of its scheduling error. Consequently, the Indiana Supreme Court affirmed the trial court's judgment. View "Bradley v. State of Indiana" on Justia Law

Joseph Corcoran was convicted of four murders by an Allen County jury, and the judge sentenced him to death as recommended by the jury. Corcoran has been involved in extensive litigation over the past 25 years, including multiple decisions from the Indiana Supreme Court and the United States Supreme Court, regarding the constitutionality of his execution. Corcoran has expressed his desire to accept his conviction and sentence, stating that he does not wish to pursue further legal challenges.The Allen Superior Court initially sentenced Corcoran to death, and the Indiana Supreme Court remanded for resentencing due to the consideration of non-statutory aggravating factors. Upon resentencing, the death sentence was reimposed and affirmed by the Indiana Supreme Court. Corcoran chose not to pursue post-conviction relief, leading to competency proceedings initiated by the State Public Defender, who argued that Corcoran was incompetent to waive post-conviction remedies. The trial court and the Indiana Supreme Court found Corcoran competent. Corcoran later filed an untimely petition for post-conviction relief, which was dismissed.The Indiana Supreme Court reviewed the case and denied the State Public Defender's motions to file successive petitions for post-conviction relief and to stay the execution. The court held that Corcoran is competent to waive post-conviction remedies and that the State Public Defender lacks standing to file the petitions without Corcoran's authorization. Additionally, the court found no reasonable possibility that Corcoran is entitled to relief, as the claims presented were procedurally defaulted and previously addressed. The court concluded that Corcoran has a rational understanding of his execution and the reasons for it, and thus, denied the motions for a stay of execution. View "Corcoran v. State" on Justia Law

AMW Investments, Inc. and Midwest Entertainment Ventures, Inc. (collectively, AMW) owned and operated an adult-entertainment venue called Theatre X. The Town of Clarksville revoked AMW’s adult-entertainment license in early 2019 due to violations of local ordinances against lewd conduct. AMW sought judicial review of the revocation in the Clark Circuit Court, which led to the Town filing counterclaims and seeking a preliminary injunction to bar AMW from operating Theatre X. The trial court issued the injunction and deferred ruling on fines pending AMW’s appeal of the injunction.The Clark Circuit Court ordered AMW to respond to the Town’s discovery requests, but AMW only objected on jurisdictional grounds, claiming the trial court lacked jurisdiction during the appeal. The trial court found AMW’s objections inexcusable and ordered compliance. AMW continued to object and withhold documents, leading the trial court to find AMW in contempt and impose a $30,000 sanction. AMW appealed the sanction, and the Indiana Court of Appeals reversed, holding that AMW’s objections were not waived.The Indiana Supreme Court reviewed the case and held that AMW’s objections were untimely and thus waived. The Court affirmed the trial court’s discovery order and sanction, stating that the trial court did not lose jurisdiction during the appeal and no stay was issued. The Court emphasized that untimely objections are presumptively waived under the trial rules, and the trial court did not abuse its discretion in refusing to excuse the waiver or in sanctioning AMW for non-compliance. The case was remanded for further proceedings consistent with the opinion. View "AMW Investments Inc. v. The Town of Clarksville" on Justia Law

R.L., a sheriff’s deputy, was charged with driving while intoxicated, but the charges were later dropped. The Indiana Law Enforcement Training Board initiated proceedings to revoke R.L.'s basic-training certificate, which is necessary for his employment as an officer. R.L. sought and obtained a court declaration and injunction preventing the board from disciplining him before the board issued a final decision.The Martin Circuit Court granted R.L.'s request for declaratory and injunctive relief, barring the board from using facts from R.L.'s expunged arrest to revoke his certificate. The board intervened and moved to vacate the order, arguing procedural errors and lack of merit. The trial court vacated its initial order but issued a second similar order. The board appealed, and the Indiana Court of Appeals reversed the trial court's decision, allowing the board to consider independent evidence of the facts underlying the expunged arrest records.The Indiana Supreme Court reviewed the case and held that the trial court erred in granting R.L.'s request for declaratory and injunctive relief. The court emphasized that R.L. must follow the Administrative Orders and Procedures Act (AOPA) to challenge the board's decisions and that he failed to exhaust administrative remedies before seeking judicial intervention. The court reversed the trial court's judgment and remanded with instructions to dismiss R.L.'s declaratory-judgment action, reinforcing the necessity of exhausting administrative remedies before seeking judicial review. View "Indiana Law Enforcement Training Board v. R L" on Justia Law

Christi and August Wohlt owned a company called Echo Systems, Inc., which dealt in cryptocurrencies. Upon dissolving their marriage, they agreed that August would retain all assets of the business, except for some personal electronics that Christi would keep. However, they both forgot that Echo Systems still owned some cryptocurrencies. The issue was whether this oversight made their agreement ambiguous regarding the ownership of these cryptocurrencies.The Delaware Circuit Court dissolved their marriage and incorporated their property settlement agreement. Later, August discovered the forgotten cryptocurrencies and informed Christi. Christi then filed a motion to address the omitted assets and requested the court to divide the cryptocurrencies and increase August’s child support obligation. August moved for partial summary judgment, arguing that the agreement unambiguously awarded him all of Echo Systems’ assets, including the cryptocurrencies. The trial court denied his motion, finding factual issues regarding the parties' knowledge of the cryptocurrencies. After an evidentiary hearing, the court awarded Christi half the value of the cryptocurrencies, concluding the agreement was ambiguous.The Indiana Court of Appeals reversed the trial court’s decision, holding that the property settlement agreement unambiguously awarded the cryptocurrencies to August. The court affirmed the trial court’s rulings on other issues, including attorney and expert fees.The Indiana Supreme Court reviewed the case and agreed with the Court of Appeals that the agreement unambiguously transferred all of Echo Systems’ assets, including the cryptocurrencies, to August. The court emphasized that the term “all” was not ambiguous and that the parties’ agreement intended to settle all their assets with finality. The court reversed the trial court’s denial of August’s motion for partial summary judgment and affirmed the Court of Appeals' decision on the remaining issues. View "Wohlt v. Wohlt" on Justia Law

A highway construction project in Johnson County, Indiana, required the widening of State Road 37 and the closure of an intersection at Fairview Road. The State initiated an eminent domain action to acquire a 0.632-acre strip of land from Franciscan Alliance, Inc., and the owners of easement rights over the strip, including The Market Place at State Road 37, LLC, and SCP 2010-C36-018, LLC, contested the action and sought damages due to changes in traffic flow from the intersection closure.The Johnson Superior Court appointed appraisers who valued the land and assessed damages. A jury trial followed, resulting in a verdict awarding $680,000 to Franciscan and $1,500,000 to SCP. The State appealed, arguing that damages for changes in traffic flow were not compensable. The Indiana Court of Appeals reversed the trial court's judgment, holding that the damages awarded were erroneous under existing caselaw on circuity of travel and traffic flow. Franciscan and SCP petitioned for transfer, which the Indiana Supreme Court granted.The Indiana Supreme Court reaffirmed the rule that when a road-improvement project leaves a property’s access points unchanged, a landowner cannot recover damages from changes in traffic flow, as these do not result from the taking of a property right. The Court held that the State’s construction project did not affect the owners’ access points to their properties, and thus, damages from the intersection closure were not compensable. The Court reversed the trial court’s judgment and remanded for proceedings to determine the just compensation owed to Franciscan for the 0.632-acre strip of land. View "State v. Franciscan Alliance, Inc." on Justia Law