Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of criminal confinement and battery. Defendant appealed, arguing that his convictions violated the prohibition against double jeopardy under the Indiana Constitution and common law and seeking sentence review. The Supreme Court vacated Defendant’s conviction for battery and its concurrent three year sentence but affirmed Defendant’s conviction and eight year sentence for criminal confinement, holding (1) Defendant’s two convictions do not violate the common law but do violate the Double Jeopardy Clause of the Indiana Constitution under the actual evidence test; and (2) Defendant failed to demonstrate that his sentence is inappropriate for his character and the nature of the offense. View "Hines v. State" on Justia Law

In 2000, Appellant was diagnosed with paranoid schizophrenia. In 2004, while unprovoked, Appellant fired a shotgun several times at multiple vehicles, including a police cruiser. The jury returned verdicts of guilty but mentally ill on four counts of Class A felony attempted murder. Appellant was sentenced to an aggregate sentence of 120 years. The court of appeals reversed Appellant’s convictions, concluding that (1) jury clearly erred in rejecting Appellant’s insanity defense, and (2) the admission of evidence regarding Appellant’s post-arrest silence and request for counsel, and the prosecution’s closing arguments relying on those instances as evidence of sanity, violated Appellant’s constitutional due process rights. The Supreme Court granted the State’s petition to transfer, thereby vacating the Court of Appeals opinion, and affirmed the the jury's verdict finding Appellant guilty but mentally ill, holding (1) there was sufficient evidence for a jury to draw a reasonable inference that Defendant was able to appreciate the wrongfulness of his conduct at the time of the offense; (2) there was no due process violation; and (3) Appellant’s sentence was appropriate. View "Myers v. State" on Justia Law

In 2010, due to a large budget deficit, Franklin Township Community School Corporation voted to discontinue transportation services for the majority of students attending its public schools. Parents of students who attend public schools in Franklin School Corporation brought a class action suit seeking a declaratory judgment that discontinuing transportation is prohibited under the Education Clause of the Indiana Constitution. The trial court granted summary judgment in favor of Franklin School Corporation. The Supreme Court affirmed, holding that the Indiana Constitution does not mandate school corporations to provide transportation to and from school, and therefore, Franklin School Corporation did not violate a constitutional mandate. View "Hoagland v. Franklin Township Cmty. Sch. Corp." on Justia Law

Police officers asked Defendant to step out of his truck during a traffic stop and made their permission conditional on a pat-down. During the pat-down, the officers discovered marijuana on Defendant’s person. Defendant then admitted he had a pipe in his truck. Defendant was charged with possession of marijuana and possession of paraphernalia. The trial court granted Defendant’s motion to suppress the marijuana and the pipe. The Court of Appeals affirmed on different grounds, concluding that Defendant’s consent to the pat-down was invalid because the choice of being patted down as a condition of exiting the vehicle or else remaining in the vehicle unsearched was inherently coercive and rendered Defendant’s consent involuntary. The Supreme Court reversed, holding (1) it is not inherently coercive for police to give conditional permission to step out of the vehicle, subject to the motorist’s consent to a pat-down; and (2) any extension of the search from Defendant’s initial consent was the product of his subsequent consent and not of improper police conduct. View "State v. Cunningham" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and felony arson resulting in serious bodily injury. The jury recommended the death penalty, and the trial court sentenced Defendant accordingly. The Supreme Court affirmed the convictions and sentence, holding (1) the trial court did not err in excluding a prison administration expert from testifying that Defendant could safely be incarcerated for the remainder of his natural life; (2) there was sufficient evidence to support the convictions; (3) the trial court did not commit reversible error in refusing to excuse twelve jurors for cause; (4) Defendant was not entitled to a mistrial after a juror placed a note in the jury room thanking jurors for their service to the deceased; (5) the district court did not err in refusing to suppress statements Defendant made to police; (6) the trial court did not abuse its discretion in sentencing Defendant to death; and (7) the jury and the trial court properly considered and weighed Defendant’s offered mitigating circumstances. View "Weisheit v. State" on Justia Law

After a jury trial, Defendant was found guilty of attempted murder. At Defendant’s trial and during final instructions, the trial court properly instructed the jury on the crime of attempted murder. Although Defendant was not charged as an accomplice to attempted murder, and his attempted murder charge was not explicitly premised on a theory of accomplice liability, the trial court also instructed the jury on accomplice liability. During closing arguments, the State argued both direct liability and accomplice liability theories for the attempted murder. The verdict form also did not distinguish between Defendant’s potential direct liability or accomplice liability for the attempted murder. The jury found Defendant guilty as charged. Defendant appealed, arguing that the trial court erred by not instructing the jury that it must find he had the specific intent to kill when he knowingly or intentionally aided, induced, or caused another person to attempt murder. The Supreme Court reversed the conviction, holding that the trial court committed fundamental error by giving an instruction permitting the jury to convict Defendant of attempted murder as an accomplice without the specific intent to kill. View "Rosales v. State" on Justia Law

Defendant was intoxicated when he crashed his vehicle into a service vehicle, killing the service truck driver. After a trial, Defendant was found guilty of operating a motor vehicle while intoxicated in a manner endangering a person and operating a motor vehicle while intoxicated, but the jury deadlocked on the most serious of Defendant’s charges. Defendant moved for judgment on the verdicts. The trial court denied Defendant’s motion to compel an entry of judgment on the verdicts and permitted the State to retry Defendant on all counts. After a second trial, the jury once again found Defendant guilty of the lesser offenses and also found Defendant guilty of the more serious offenses of causing death when operating a motor vehicle while intoxicated as class B and C felonies. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s first deadlock on the most serious of his charges, paired with its finding of guilt as to the lesser offenses, did not equate to an implied acquittal of those more serious offenses; and (2) the prohibition against double jeopardy was not violated when Defendant was retried on the greater offenses upon which the jury was deadlocked. View "Cleary v. State" on Justia Law

Mrs. Bridgewater, a Fishers Adolescent Catholic Enrichment Society, Inc. (FACES) member parent, filed a complaint with the Indiana Civil Rights Commission, alleging that FACES refused a reasonable accommodation for her allergic daughter by not serving her beef instead of chicken at a social event, therefore discriminating against her due to her disability. FACES subsequently expelled the Bridgewater family. Mrs. Bridgewater then filed a second complaint with the Commission, alleging that FACES unlawfully retaliated against her family for filing the disability discrimination claim. FACES filed a motion to dismiss on the basis that the Commission did not have subject-matter jurisdiction because FACES was a religious organization, not an educational one. The Commission denied the motion to dismiss and awarded judgment in favor of Mrs. Bridgewater on the retaliatory discrimination claim. The Supreme Court vacated the Commission’s final order, holding that the Commission lacked authority to take any action other than the dismissal of these claims because the incident giving rise to the claims was not related to education and was thus not within the Commission’s prerequisite statutory authority. Remanded to grant FACES’s motion to dismiss as to both claims. View "Fishers Adolescent Catholic Enrichment Soc’y, Inc. v. Bridgewater" on Justia Law

Defendant was convicted under Indiana’s public intoxication statute of being intoxicated in a public place and engaging in annoying conduct. Defendant appealed, arguing that the term “annoys” in the public intoxication statute is unconstitutionally vague and that there was insufficient evidence to sustain his conviction. The Supreme Court vacated Defendant’s conviction for misdemeanor public intoxication, holding (1) Indiana’s public intoxication statute is constitutional when a reasonableness standard is applied to the term “annoys”; and (2) in applying this reasonableness standard, there was insufficient evidence to sustain Defendant’s conviction for public intoxication. View "Morgan v. State" on Justia Law

Plaintiffs, an exclusive-agency union and several of its members and officers (collectively, the Union), filed a complaint against the Attorney General and the Commissioner of the Indiana Department of Labor (collectively, the State), seeking a declaratory judgment that certain provisions of the Indiana Right to Work Law were unconstitutional. The trial court granted relief on the Union’s claim that two provisions of the Indiana Work Law violated Article 1, Section 21 of the Indiana Constitution, which provides that “[no] person’s particular services shall be demanded, without just compensation.” The first challenged provision of the Indiana Work Law prohibits employers from requiring union membership or the payment of monies as a condition of employment, and the second provision makes the knowing or intentional violation of the first provision a Class A misdemeanor. The Supreme Court reversed, holding that the two provisions do not violate Section 21 because the challenged provisions do not constitute a demand by the State for particular services. View "Zoeller v. Sweeney" on Justia Law