Justia Indiana Supreme Court Opinion Summaries

Plaintiff brought several claims against multiple defendants arising out of his incarceration for a probation violation that occurred after his term of probation had expired. The trial court dismissed Plaintiff’s claims against all defendants. The court of appeals affirmed. Plaintiff sought transfer, contending that his claim against four individual probation officers under 42 U.S.C. 1983 was incorrectly dismissed for failure to state a claim. The Supreme Court granted transfer and reversed dismissal of Plaintiff’s section 1983 claim against the individually-named probation officers, holding that Plaintiff’s complaint stated a claim for relief under section 1983 against these defendants. View "Thornton v. State" on Justia Law

Plaintiffs, as a certified class, challenged the constitutionality of the program utilized by the Indiana Bureau of Motor Vehicles (BMV) in the processing of applications for personalized license plates (PLPs), arguing that the decision making process used in denying or revoking PLPs violates the First Amendment and the Due Process Clause. The trial court granted summary judgment in favor of the class, concluding that the statute that authorizes the BMV to refuse to issue PLPs and its related policies are vague, overbroad, and lacking in content-neutrality and that the Bureau violates due process safeguards by providing insufficient reasons for a denial or revocation of a PLP. The Supreme Court reversed, holding (1) PLPS are government speech; and (2) therefore, the statute and policies at issue in this case are constitutional. View "Comm’r of Ind. Bureau of Motor Vehicles v. Vawter" on Justia Law

Defendant was charged with possessing, selling and dealing in the chemical compound designated XLR11 and dealing and conspiracy to commit dealing in look-alike substances. Defendant filed a motion to dismiss the charges, claiming that the information failed to reference the Indiana Board of Pharmacy’s Emergency Rule 12-493(E), which criminalized XLR11; the applicable statutory schemes were void for vagueness; and the General Assembly could not delegate to the Pharmacy Board the power to criminalize XLR11. The trial court denied Defendant’s motion. The Supreme Court (1) affirmed the trial court’s denial of Defendant’s motion to dismiss the charges against him under the applicable statutes, holding that there was no constitutional or statutory infirmity to any of the charges; but (2) dismissed the XLR11-related charges, holding that the charging information was inadequate with respect to those charges. Remanded. View "Tiplick v. State" on Justia Law

Kentucky attorney Suzanne Cassidy represented Ernest Smith in Kentucky in a federal employment-discrimination lawsuit against his former employers, Dennis Boyer and Richard Smith, and other defendants. Attorney Cassidy subsequently dismissed Boyer and Richard from the suit. Thereafter, Boyer and Richard sued Ernest and Attorney Cassidy in an Indiana state court, alleging, among other tort claims, that the Kentucky suit was frivolous and constituted malicious prosecution. The trial court granted summary judgment in favor of Ernest and Attorney Cassidy, determining, as relevant to this appeal, that it lacked personal jurisdiction over Attorney Cassidy. The Supreme Court affirmed the trial court on the personal jurisdiction issue, holding that Indiana lacked specific jurisdiction over Attorney Cassidy because her conduct did not establish a substantial connection between herself and the state of Kentucky, and thus could not support personal jurisdiction. View "Boyer v. Smith" on Justia Law

After a jury-waived trial, Defendant was found guilty of robbery and criminal confinement. The trial court used the same evidence, namely, Defendant’s act of being armed with a deadly weapon, to enhance both of his convictions from class C to class B felonies. Defendant appealed, arguing that the two convictions violated Indiana’s constitutional ban on double jeopardy because the force used to support the robbery conviction was coextensive with the force used to support the confinement conviction. The court of appeals affirmed. The Supreme Court affirmed, holding that committing two or more separate offenses each while armed with the same deadly weapon is not within the category of rules precluding the enhancement of each offense based on “the very same behavior.” View "Sistrunk v. State" on Justia Law

After a jury trial, Defendant was convicted of class A felony child molesting. The court of appeals reversed Defendant’s conviction and remanded for a new trial, holding that the trial court abused its discretion in denying Defendant’s motion to compel the victim’s mother to answer a deposition question about an incident in the victim’s past and in excluding from evidence the substance of a phone conversation with the victim’s mother in which she and the victim discussed the incident. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding that the trial court’s alleged errors, even if considered violations of Defendant’s Sixth Amendment right to confrontation, were harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary, a class C felony. The Court of Appeals reversed the conviction, finding that the conviction was obtained through the State’s knowing use of perjured testimony. The Supreme Court granted transfer, thus vacating the opinion of the Court of Appeals, and affirmed the conviction, holding (1) Defendant’s due process rights were not implicated by the inconsistent testimony, as the State notified opposing counsel and the court of the conflicting testimony and proactively drew attention to the discrepancies in the testimony throughout the trial, thus permitting the jury to fully function as an informed fact finder; and (2) the incredible dubiosity rule was not applicable to this case. View "Smith v. State" on Justia Law

After I.B. and W.B. were removed from their parents, both their paternal and maternal grandmothers petitioned to adopt them. The trial court found that it was in the best interests of the children for the maternal grandmother and her fiancé to adopt them the maternal grandmother had a prior felony conviction that statutorily disqualified her from adopting. The court of appeals affirmed, concluding that the statutory disqualification was unconstitutional as applied because it amounted to an irreubttable presumption in violation of due process. The Supreme court granted transfer and reversed, holding that the statute is constitutional, despite its harsh consequences under the facts of this case. View "In re Adoption of I.B." on Justia Law

Defendant was living in the residence of an individual who was home home detention under Community Corrections supervision when community corrections officers went into the residence to conduct a warrantless search to ensure Sullivan’s compliance with the conditions of the program. The ensuing search uncovered illegal drugs in the common areas in the residence as well as drugs and drug paraphernalia in Defendant’s private bedroom. Defendant was charged with maintaining a common nuisance and other drug-related offenses. The trial court granted Defendant’s motion to suppress in part, concluding that the Community Corrections officers had consent to search the common areas of the residence but not Defendant’s private bedroom. The Supreme Court reversed, holding that all of the evidence seized from the compliance search was the result of an improper entry and search because the home detention participant had agreed to written conditions of his participation that consented only to searches upon probable cause, which was wholly lacking in this case. Remanded with instructions to grant the motion to suppress in its entirety. View "State v. Vanderkolk" on Justia Law

After a jury trial, Defendant was found guilty of three counts of murder. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s conviction and death sentence but remanded with instructions to issue a new sentencing order consistent with this opinion, holding (1) the trial court did not err by denying Defendant’s for-cause challenges to certain prospective jurors; (2) the trial court did not err in denying Defendant’s motions for mistrial; (3) the trial court did not abuse its discretion in instructing the jury; (4) the trial court did not err by refusing to allow a witness to answer a question posed by a juror; (5) the State did not commit prosecutorial misconduct during closing arguments in the penalty phase of trial, but the remarks were not so prejudicial to Defendant’s right of fundamental due process as to make a fair trial impossible; (6) Defendant’s death sentence was appropriate; and (7) the trial court exceeded its statutory authority by ordering Defendant’s death sentences to be served consecutively. View "Isom v. State" on Justia Law