Justia Indiana Supreme Court Opinion Summaries

Articles Posted in 2012
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In this case, Plaintiff prevailed on its Access to Public Records Act (Act) claim against a public agency and an intervening private party. As required by statute, the trial court awarded Plaintiff attorney's fees. The fees were awarded against both the public agency and the intervening private party, jointly and severally. The private party argued that the Act does not contemplate the award of attorney's fees against an intervening private party and that only the public agency should be liable for the fees. The Supreme Court affirmed the trial court's award of attorney's fees to Plaintiff, holding (1) the Act, in light of the legislature's liberal-construction mandate and the statute's underlying policy, permits the award of attorney's fees against an intervening private party; and (2) in this case, the trial court did not abuse its discretion in its apportionment of liability. View "Shepherd Props. Co. v. Int'l Union of Painters & Allied Trades" on Justia Law

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This case involved a property dispute between an individual church congregation, Olivet Presbyterian Church, and the denominational organization with which it was previously affiliated, the Presbyterian Church (U.S.A.), and the latter's subsidiary organizations, the plaintiffs in this action, the Presbytery of Ohio Valley and the Synod of Lincoln Trails of the Presbyterian Church (U.S.A.), Inc. (collectively, "Presbytery"). The trial court granted summary judgment rejecting the Presbytery's claims of express and implied trust and holding that the disputed property was solely owned by Olivet. The Presbytery appealed both the denial of its motion for summary judgment and the granting of Olivet's motion. The Supreme Court reversed, holding that genuine issues of material fact arose from the inferences flowing from the stipulated designated evidence and that neither Olivet nor the Presbytery was entitled to the full relief sought in their respective motions for summary judgment. Remanded. View "Presbytery of Ohio Valley, Inc. v. OPC, Inc." on Justia Law

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Defendant was convicted of unlawful possession of a firearm by a serious violent felon and found to be a habitual offender. The court of appeals affirmed. The Supreme Court granted transfer, thereby vacating the opinion of the court of appeals. The Supreme Court vacated the habitual-offender enhancement, holding that the trial court erred in denying Defendant's motion to dismiss the habitual-offender allegation, as the habitual-offender enhancement to Defendant's sentence for unlawful possession of a firearm by an SVF constituted an impermissible double enhancement. The Court then affirmed Defendant's conviction of unlawful possession of a firearm by an SVF and his sentence for that offense. Remanded for resentencing. View "Dye v. State" on Justia Law

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This case involved a seventeen-and-a-half-year-old who murdered his ten-year-old brother. Defendant confessed to the crime and pleaded guilty to murdering his brother, Conner, while he was babysitting. The trial court judge sentenced Defendant to life without parole. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court did not err in allowing the testimony of a medical doctor who suggested that Defendant had traits of a person with psychopathy; (2) the trial court properly weighed the aggravating and mitigating factors in this case; (3) based on the age of Conner, and the particularly heinous nature of the crime, a sentence of life without parole was appropriate under Indiana Appellate Rule 7(B); and (4) under the facts of this case, the imposition of a life-without-parole sentence on a person under the age of eighteen who has been convicted of murder did not violate either the United States or Indiana Constitution. View "Conley v. State" on Justia Law

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Defendant was prosecuted for the death of her two-year-old cousin and later convicted of one count of murder, two counts of neglect of a dependent, one count of battery, and one count of misdemeanor false informing. Defendant was sentenced to life imprisonment without the possibility of parole for murder plus a total of five additional years for the other crimes. Defendant challenged her sentence on appeal. The Supreme Court revised Defendant's sentence, holding (1) the appropriate sentence for this defendant was sixty-five years, the maximum term of years for murder; and (2) the prosecutor committed misconduct in this case, but because Defendant's sentence was revised from life without parole to a term of sixty-five years, no further relief was warranted for Defendant's prosecutorial misconduct claim. Remanded. View "Castillo v. State" on Justia Law

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Petitioner appealed a Marshall County Drainage Board order assessing him a portion of a drain-reconstruction project's costs, contending that he received no benefit from the project because his land was adequately drained before the reconstruction. The Supreme Court affirmed the assessment because under Indiana law, holding (1) Indiana law allows a drainage board to assess a benefit to a tract of land based solely on the fact that surface water from that land flows into the regulated drain for which the assessment is levied; and (2) as a result, the trial court's order - which found that the Board's decision to attribute a benefit to Petitioner on this bases was not arbitrary, capricious, or unlawful, and was supported by substantial evidence - was not erroneous. View "Crowel v. Marshall County Drainage Bd." on Justia Law

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Parents of a young man killed in a helicopter accident in British Columbia appealed an Indiana trial court's dismissal of their complaint in favor of the Canadian forum, arguing that their claim should be tried in Indiana because they would only be entitled to nominal damages under British Columbia law. The Supreme Court affirmed the trial court's judgment after adopting the reasoning of the U.S. Supreme Court in Piper Aircraft Co. v. Reyno, holding that British Columbia provided an available and adequate forum under applicable law, and the trial court did not otherwise abuse its discretion in dismissing the complaint on the ground of forum non conveniens. View "Otieno v. Rolls-Royce Corp." on Justia Law

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Defendant pled guilty to operating a motor vehicle after having his license forfeited for life. On the same day, the trial court placed him on home detention under the supervision of a community-corrections program in January 2010. Defendant appealed, arguing that the introduction of certain hearsay evidence at the hearing revoking his community-corrections placement violated his due process right to confrontation. The Supreme Court affirmed the judgment of the trial court, holding that the hearsay evidence introduced at the hearing was substantially trustworthy, and therefore, Defendant's due process right to confrontation was not violated by the admission of the evidence. View "Smith v. State" on Justia Law

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Indiana's motor vehicle statutes provide a carve-out through which individuals whose driving privileges are suspended may still commute, provided the device they use to do so meets certain requirements. One requirement is that the maximum design speed of such a device may not exceed twenty-five miles per hour. Defendant in this case was charged with operating a motor vehicle as a habitual traffic violator. The only evidence admitted at trial as to the above requirement was that Defendant was traveling forty-three miles per hour on a flat, dry surface. The trial court found Defendant guilty as charged and revoked his driving privileges for life. The Supreme Court affirmed, holding (1) the statutory scheme was not unconstitutionally vague; and (2) on the basis of a stipulation that Defendant was traveling forty-three miles per hour, and in the face of no rebuttal evidence, it was impossible to claim that no reasonable fact-finder could find beyond a reasonable doubt that Defendant had a maximum design speed in excess of twenty-five miles per hour. View "Lock v. State" on Justia Law

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This appeal was the latest iteration of a decade-long dispute between the Miller Brewing Company and the Indiana Department of Revenue over Miller's Indiana adjusted gross income tax liability. The Department here appealed the tax court's determination that Miller owes no tax on certain sales to Indiana customers. The Supreme Court reversed, holding (1) the relevant statute was unambiguous; and (2) an example in the statute used by Miller in its argument was specifically designated as an example and not a rule and did not have the force of law, and therefore, the tax court erred in determining that the example operated to exempt Miler from liability for Indiana tax on income from sales of good delivered by common carrier to Indiana customers. View "Ind. Dep't of Revenue v. Miller Brewing Co." on Justia Law