Justia Indiana Supreme Court Opinion Summaries

A commercial real estate broker and consultant partnered with three brothers who owned an architecture and construction company to develop and lease a commercial property. They planned to form a limited liability company (LLC) as equal members, contributing professional services and cash, but did not formalize their agreement in writing. After a dispute arose over a broker commission, the brothers executed a backdated operating agreement that excluded the broker from LLC membership. The broker alleged he was unfairly cut out of the deal and sued for breach of contract and unjust enrichment.The Marshall Circuit Court granted summary judgment to the brothers on the contract claim, finding that Indiana law required written confirmation for LLC membership, which the broker lacked. The court also denied the broker’s request for a jury trial on the unjust enrichment claim, holding that both the claim and the defense of unclean hands were equitable issues for the judge. After a bench trial, the court ruled against the broker on unjust enrichment, finding he failed to prove his claim and that unclean hands barred recovery.On appeal, the Indiana Court of Appeals reversed, holding that initial LLC membership could be established by oral agreement and that unjust enrichment claims for money damages were legal claims entitled to a jury trial. The Indiana Supreme Court granted transfer, vacating the appellate decision.The Indiana Supreme Court held that LLC membership under the Business Flexibility Act requires either a written operating agreement or written confirmation, and the broker was not a member as a matter of law. However, genuine factual disputes remained regarding whether the brothers breached an agreement to make him a member, precluding summary judgment. The Court also held that unjust enrichment claims for money damages are legal claims subject to a jury trial, and the unclean hands doctrine may be asserted as a defense. The judgment was vacated and the case remanded for a jury trial on both claims. View "Andrew Nemeth Properties, LLC v. Panzica" on Justia Law

M.C. arrived at the Sandra Eskenazi Mental Health Center exhibiting manic behavior. The center sought and obtained an emergency involuntary detention. Subsequently, they petitioned for a temporary commitment. During the hearing, Dr. Jayme Ahmed testified that M.C. had a prior schizophrenia diagnosis, exhibited delusional behavior, and refused medication. M.C. believed he needed to go to Washington, D.C., to broadcast a "state of emergency" and planned to call his father for bus fare. He also reported that his social security benefits had stopped. Dr. Ahmed expressed concern that M.C.'s fixation on Washington, D.C., and lack of stable income would impair his ability to provide for himself.The Marion Superior Court ordered M.C.'s temporary commitment, finding him gravely disabled. M.C. appealed, arguing insufficient evidence of his grave disability and that his case was not moot. The Indiana Court of Appeals dismissed the appeal as moot, stating M.C. failed to demonstrate particularized collateral consequences of his commitment.The Indiana Supreme Court reviewed the case, noting that their recent decision in J.F. v. St. Vincent Hosp. and Health Care Ctr., Inc. established that appeals of temporary commitment orders are not moot unless the appellee shows no collateral consequences. The Court found the Court of Appeals' decision conflicted with J.F. by declaring the appeal moot and improperly placing the burden on M.C. to show collateral consequences. The Indiana Supreme Court vacated the Court of Appeals' decision and affirmed the trial court's temporary commitment order, concluding that sufficient evidence supported M.C.'s commitment. View "In re Commitment of M.C." on Justia Law

In January 2024, seventeen-year-old B.H. was held at Logansport Juvenile Correctional Facility. After being informed of a minor sanction, B.H. allegedly threatened and struck an officer, causing a lacerated nose. B.H. later explained he was upset due to news about his parents. Three months later, after B.H. turned eighteen, the State sought approval to file a juvenile delinquency petition for battery on a public safety officer. The trial court denied the request, citing "LACK OF JURISDICTION." The State filed a motion to correct error, arguing the court had jurisdiction since B.H. was under twenty-one and the act occurred before he turned eighteen. The court denied the motion, stating the case was filed after B.H. turned eighteen.The State then petitioned for an interlocutory appeal, which the trial court granted. The Indiana Court of Appeals accepted jurisdiction and reversed the trial court's decision, treating the order as a final judgment. The State missed the thirty-day deadline for filing its notice of appeal, but the Court of Appeals did not dismiss the appeal. B.H. petitioned for transfer to the Indiana Supreme Court, which was granted, vacating the Court of Appeals' opinion.The Indiana Supreme Court reviewed the case de novo. The court found that the trial court had subject-matter jurisdiction but focused on whether the State had the authority to appeal the order and whether the appeal was timely. The court concluded that the State forfeited its right to appeal by filing an untimely notice of appeal and failed to present extraordinarily compelling reasons to reinstate that right. Consequently, the Indiana Supreme Court dismissed the appeal. View "State of Indiana v. BH" on Justia Law

Franklyn Neter-Nu, a truck driver, visited Methodist Hospital in Gary, Indiana, complaining of nausea and vomiting. He was treated with IV fluids and medications, but the IV was twice found detached from his arm by Nurse Morgan Mittler, who then placed it in his right foot without proper training or a doctor's order. Neter-Nu later experienced pain in his foot, and despite an x-ray showing no issues, he was discharged. After traveling to Iowa, he sought emergency care for blackened toes and was eventually referred for a below-the-knee amputation.Neter-Nu filed a complaint against Dr. Zainab Abbas, Nurse Mittler, and Methodist Hospital, alleging negligence. A jury found in favor of Neter-Nu, awarding him $11,000,000, which was reduced to the statutory cap of $1,250,000. The trial court also awarded $79,993.40 in prejudgment interest. The Indiana Court of Appeals reversed the jury verdict, citing errors in denying Methodist’s Rule 50(A) motion, jury instructions, and evidentiary rulings, and remanded for a new trial.The Indiana Supreme Court reviewed the case and held that the trial court erred in denying Methodist’s Rule 50(A) motion and in its jury instructions, but these errors did not necessitate reversing the jury verdict due to joint-and-several liability. The court found that the trial court did not abuse its discretion in refusing the Providers’ proposed jury instructions on superseding cause and hindsight, nor in excluding certain medical records and emails. The Supreme Court affirmed the jury verdict but reversed and remanded for the trial court to grant Methodist’s Rule 50(A) motion and recalculate prejudgment interest based on the Providers’ statutory liability. View "Abbas v. Bilal Neter-Nu" on Justia Law

Chris Kelly was pulled over in August 2020 for minor traffic infractions, leading to the suspension of his driver's license. Despite efforts by a prosecutor to correct the record, Kelly was pulled over again in January 2021 for driving on a suspended license. He continued to face issues with his suspended license, which he claimed caused him to lose a job opportunity and incur over $1,000 in expenses. Kelly alleged that despite acknowledging the error, the Bureau of Motor Vehicles (BMV) failed to correct his driving record.Kelly sued the BMV in January 2023 for negligently failing to correct his driving record, seeking costs, damages, and interest. The BMV moved to dismiss the claim, arguing that the statutes did not create a private right of action. The Marion Superior Court granted the BMV's motion and dismissed the complaint without prejudice. The Indiana Court of Appeals reversed, finding that Kelly had sufficiently alleged a common-law negligence claim and that the relevant statute conferred a private right of action. The BMV petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court reviewed the case and affirmed the trial court's dismissal. The court held that the Legislature did not intend to create a private right of action under the relevant statutes, as the material error review process and the Administrative Orders and Procedures Act (AOPA) provided independent enforcement mechanisms. Additionally, the court found that the BMV's duty to maintain driving records primarily served public safety rather than individual drivers. The court also concluded that Kelly failed to establish a common-law duty for the BMV to maintain accurate records. View "Kelly v. Indiana Bureau of Motor Vehicles" on Justia Law

An adoptive mother, J.S., declined to take her teenage son, E.K., back into her home due to his history of violent behavior towards her and his siblings. The Indiana Department of Child Services (DCS) sought a CHINS 1 adjudication, alleging that the mother failed to provide necessary shelter. At the fact-finding hearing, the mother requested alternative CHINS adjudications based on the child endangering himself or others (CHINS 6) or his fetal alcohol syndrome diagnosis (CHINS 10). The trial court deferred to DCS’s filing decision and entered a CHINS 1 adjudication.The Whitley Circuit Court initially awarded DCS emergency custody of E.K. and later adjudicated him under CHINS 1 after the father admitted to the allegations. The mother contested the CHINS 1 adjudication, leading to a fact-finding hearing. The trial court found that E.K. posed a danger to himself and others but still adjudicated him under CHINS 1, citing the mother’s refusal to provide necessary shelter. The Indiana Court of Appeals affirmed the trial court’s decision.The Indiana Supreme Court reviewed the case and vacated the CHINS 1 adjudication, finding insufficient evidence that the mother either had the financial means to provide a safe home or failed to seek other reasonable means to do so. The court held that the trial court should have independently assessed whether a CHINS 6 or 10 adjudication was appropriate, rather than deferring to DCS. Due to procedural shortcomings, including the lack of proper notice and participation for E.K., the Supreme Court remanded the case for further proceedings consistent with its opinion. View "J.S. v. Department of Child Services" on Justia Law

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

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

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