Justia Indiana Supreme Court Opinion Summaries

Defendant pled guilty to two counts of child molesting as class A felonies. The sentencing range for a class A felony is from twenty to fifty years, and the advisory sentence is thirty years. The trial court imposed consecutive advisory sentences for an aggregate term of sixty years. The court of appeals revised the sentences by ordering them to run concurrently pursuant to Ind. App. R. 7(B), thus reducing the aggregate term from sixty to thirty years. The Supreme Court affirmed the sentence imposed by the trial court, holding that the original sentence was not inappropriate under Rule 7(B) and did not warrant appellate revision. View "Merida v. State" on Justia Law

Defendant was convicted of attempted child molesting, a class A felony. The sentencing range for a class A felony is twenty to fifty years incarceration, and the advisory sentence is thirty years. The trial court imposed a sentence of forty years with five years suspended. The court of appeals revised the sentence to twenty years, the minimum term. The Supreme Court (1) affirmed the sentence imposed by the trial court, holding that the sentence was not inappropriate under Ind. App. R. 7(B) and did not warrant appellate revision; and (2) summarily affirmed the court of appeals in all other respects. View "Lynch v. State" on Justia Law

In 2008, a jury awarded John Doe $150,000 in punitive damages as part of a judgment in Doe's lawsuit against a priest for childhood sexual abuse. The priest moved to reduce the punitive damages pursuant to the statutory cap. The trial court denied the motion, holding that the statutory cap and allocation statutes violated the State Constitution's separation of governmental powers provision and right to a jury trial in civil cases provision. The State subsequently intervened. In 2011, the trial court issued an order declaring that the statutory cap and allocation statutes violated the separation of powers and right to a jury trial. The State appealed. The Supreme Court reversed, holding that the statutes did not violate the Indiana Constitution. Remanded with instructions to grant the priest's motion to reduce the punitive damages to the statutory maximum. View "State v. Doe" on Justia Law

Vincennes Indiana Girls, Inc. (VIG) deeded Camp Wildwood to the predecessor of Girl Scouts of Southern Illinois, Inc. (GSSI) on the condition that the property be used for scouting purposes for forty-nine years. The deed provided that ownership of the campground would revert to VIG if the scouting-use condition was breached during that time. After forty-four years, GSSI stopped using the camp as a Girl Scout facility and decided to sell. VIG sued to quiet title to Camp Wildwood and enjoin GSSI from selling the camp until the forty-nine-year period had expired. The trial court granted summary judgment quieting title in VIG. At issue on appeal was whether the forty-nine-year land use limitation was enforceable despite a subsequently enacted statute, Ind. Code 32-17-10-2, which purported to limit reversionary clauses in land transactions to a maximum of thirty years. The Supreme Court affirmed, holding that section 32-17-10-2 was unconstitutional as applied retroactively to the land-use restriction in VIG's deed to GSSI. View "Girl Scouts of S. Ill. v. Vincennes Ind. Girls, Inc." on Justia Law

After a jury trial, Defendant was convicted of three counts of child molestation. The only substantive evidence implicating him in those crimes was a forensic nurse examiner that testified about statements made by the alleged victim, a six-year-old child who, at the time of the trial, had recanted. The Supreme Court vacated Defendant's convictions with respect to two counts of child molestation, holding (1) there was an insufficient showing that the child victim in this case was motivated to provide truthful information to her nurse, and therefore, the nurse's testimony should not have been admitted as substantive evidence against Defendant; and (2) without this testimony, the evidence against Defendant was insufficient to sustain his convictions for child molestation. Remanded for a new trial. View "VanPatten v. State" on Justia Law

Plaintiff owned and operated certain water and sewer facilities in the City of Fort Wayne. The facilities were divided into two separate geographic areas - the North System and the Aboite System. In 2002 the City passed a resolution appropriating and condemning the North System. The City assessed damages in the amount of $14,759,500. Plaintiff challenged the condemnation proceedings alleging that the City failed to follow the proper eminent domain or condemnation statutes. The trial court granted summary judgment for the City, and the Supreme Court affirmed. The City subsequently reaffirmed its initial resolution appropriating and condemning Plaintiff's North System and adopted a resolution assessing damages in the amount of $16,910,5000. Plaintiff appealed the decision to the trial court and requested a trial by jury. The trial court refused the trial request and granted the City's motion for partial judgment on the pleadings. The Supreme Court reversed, concluding that Plaintiff had a right to the trial court's review of the record which included a full evidentiary hearing before a jury. View "Util. Ctr., Inc. v. City of Fort Wayne" on Justia Law

After a jury trial, Defendant was convicted was the murders of Donna Claspell and her two daughters. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed a petition for post-conviction relief, alleging, inter alia, that he received ineffective assistance of counsel, that he was deprived of his right to an impartial jury, and that he was entitled to in camera review of the mental health records of a juror's family. The post-conviction court denied relief on all but one of Defendant's claims, modifying Defendant's sentence from death to life imprisonment without the possibility of parole. Defendant appealed the denial of his additional post-conviction request for a new trial. The Supreme Court affirmed, holding that Defendant failed to establish that the post-conviction evidence conclusively pointed to a conclusion contrary to that of the post-conviction court. View "Wilkes v. State" on Justia Law

After Mother gave birth to an infant alone at home, Boyfriend took Mother and the infant to the hospital. Medical staff noticed puncture wounds on the infant's back and notified the authorities. An ensuing investigation resulted in the removal of the infant from Mother's care. The county prosecutor subsequently petitioned the trial court for subpoenas to compel Mother and Boyfriend to give testimony relating to the home birth of the infant. The trial court issued the subpoenas. Before Mother and Boyfriend testified, their attorney moved to quash the subpoenas pursuant to their rights against self-incrimination. The court granted the motion. The trial court then granted the prosecutor's petition for use immunity. The Supreme Court reversed, holding (1) the prosecutor was not authorized to request a grant of use immunity; and (2) where, as here, no charges have been filed and no grand jury has been convened, a prosecutor may subpoena witnesses pursuant to Ind. Code 33-39-1-4, but if those witnesses invoke their constitutional right against self-incrimination, the prosecutor cannot petition the court to grant them use immunity and compel them to testify without first filing charges or convening a grand jury. View "In re Prosecutor's Subpoena re S.H." on Justia Law

Plaintiffs, several Indiana taxpayers, brought an action challenging Indiana's statutory program for providing vouchers to eligible parents for their use in sending their children to private schools. Plaintiffs contended that the school voucher program violated three provisions of the Indiana Constitution. The trial court granted Defendant-intervenors' motion for summary judgment. The Supreme Court affirmed, holding that the enacted program (1) was within the legislature's power under Ind. Const. art. VIII, 1 to provide for a general and uniform system of common schools; (2) did not violate Ind. Const. art. I, 6 by impermissibly providing direct benefits to religious institutions; and (3) did not contravene Ind. Const. art. I, 4 by requiring persons to support any place of worship, or to maintain any ministry, against Plaintiffs' consent. View "Meredith v. Pence" on Justia Law

The State charged Defendant with unlawful possession of a firearm by a serious violent felon (SVF) and sought to have Defendant's sentence enhanced under the general habitual offender statute. Defendant pled guilty to the SVF charge, and the case proceeded to trial on the habitual offender allegation. The jury found Defendant was a habitual offender, and the trial court sentenced Defendant accordingly. The court of appeals affirmed. The Supreme Court granted transfer and vacated the thirty-year enhancement the trial court had imposed under the general habitual offender statute, concluding that it constituted an impermissible double enhancement because "a double enhancement is improper where the underlying conviction is for unlawful possession of a firearm by an SVF." The Court subsequently granted rehearing and again affirmed that a person convicted of unlawful possession of a firearm by a serious violent felon may not have his or her sentence enhanced under the general habitual offender statute by proof of the same felony used to establish that the person was a serious violent felon. View "Dye v. State" on Justia Law