Justia Indiana Supreme Court Opinion Summaries

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

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