Justia Indiana Supreme Court Opinion Summaries

In these two mental health cases, the Supreme Court dismissed the appeals of the temporary commitment orders of two individuals, holding that the Probate Commissioner lacked authority to enter the commitment orders.Although the appeals were moot, the Supreme Court addressed an issue of great public importance likely to recur, that issue being whether the Commissioners lacked authority to enter the orders of civil commitment. On appeal, Appellants argued that, rather than issuing a commitment order, the Commissioner approved each order via an "approval order" that did not constitute valid commitment orders for these two mental health cases. The Supreme Court agreed, holding that the approval orders provided inadequate assurance that the Commissioner was presented with, reviewed, and approved the temporary commitment orders in the cases of the two individuals at issue here. View "In re Civil Commitment of T.W. v. St. Vincent Hospital & Health Care Center, Inc." on Justia Law

In this involuntary civil commitment proceeding, the trial court accepted an invalid waiver of A.A.’s right to personal appear, and that error was not harmless.A.A.’s attorney waived A.A.’s right to appear, and the involuntary commitment hearing proceeded without him. The trial court ultimately ordered involuntary civil commitment. The Supreme Court reversed and remanded for the trial court to vacate the regular involuntary-commitment order, holding (1) a mentally competent civil-commitment respondent may relinquish the right to appear with a knowing, voluntary, and intelligent waiver, but an attorney may not waive the right to appear on the respondent’s behalf; (2) if the trial court independently waives a respondent’s presence at a commitment hearing, it must do so at the outset of the proceeding; (3) an improper waiver determination is subject to harmless-error review; and (4) in this case, the trial court did not make a proper waiver finding at the outset of A.A.’s involuntary civil-commitment proceeding, and the error was not harmless. View "A.A. v. Eskenazi Health/Midtown CMHC" on Justia Law

After a civil commitment hearing, the trial judge declared that, by clear and convincing evidence, T.K. was both dangerous and gravely disabled. The court then ordered T.K. to be involuntarily committed. The court of appeals affirmed. The Supreme Court granted transfer and reversed, holding that the evidence presented at the civil commitment hearing was insufficient to establish by clear and convincing evidence that T.K. was either dangerous or gravely disabled, and therefore, the civil commitment of T.K. was improper. View "In re Civil Commitment of T.K." on Justia Law

At issue in this case was whether the certificates of death that doctors, coroners, and funeral directors file with county health departments under Ind. Code 16-37-3 are public records that the public may freely obtain from county health departments. In 2012, Rita Ward sent a letter to the Vanderburgh County Health Department requesting certain copies of records created under Ind. Code 16-37-3-3 and maintained by the Department. The Department denied the request. The Evansville Courier & Press newspaper subsequently requested access to certain Vanderburgh County death records. The Department denied the request. Thereafter, Ward and the Courier & Press sued the Department, arguing that the death certificates were public records covered by the Indiana Access to Public Records Act. The trial court entered judgment in favor of the Department. The Supreme Court reversed, holding that death certificates are public records that a county health department must provide public access to under the Act. View "Evansville Courier & Press v. Vanderburgh County Health Dep’t" on Justia Law

An Estate filed an adult wrongful death medical malpractice action against a nursing home. The Estate settled its claim against the nursing home for $250,000, the maximum liability of the health care provider under Indiana’s Medical Malpractice Act (MMA). Thereafter, the Estate filed a petition to determine the amount of excess damages it was due from the Indiana Patient’s Compensation Fund. The Estate and the Fund agreed on the amount of damages but left the attorney fee component of damages for determination by the trial court. The trial court ordered the Fund to pay the Estate $50,440 for attorney fees. The Fund appealed, arguing that, in an action to recover for the wrongful death of an adult, the fifteen percent limit on attorney fees imposed by the MMA (the "fee cap provision") should be applied such that the Fund should not be required to pay a claimant an amount for attorney fees exceeding fifteen percent. The Supreme Court affirmed, holding that the fee cap provision applies to cap the fees that the plaintiff’s lawyer may charge as to the award the client receives from the Fund but does not lessen the Fund’s liability to a claimant. View "Ind. Patient's Comp. Fund v. Holcomb" on Justia Law

Sara Townsend and A.S. were co-workers. Townsend completed an application to initiate a process to seek immediate emergency treatment for A.S., alleging that A.S. was a threat to herself or others. A trial court judge issued a warrant for A.S.’s detention and treatment. Doctors at the hospital where A.S. was subsequently detained, however, determined that there was no cause to continue detaining A.S. and discharged her. Thereafter, the trial judge found Townsend in contempt of court and imposed sanctions. The court of appeals (1) concluded that the trial court lacked statutory authority to find Townsend in indirect civil contempt, but (2) upheld the trial court’s order directing Townsend to pay A.S.’s hospital bill and attorney fees as a legitimate exercise of the trial court’s inherent powers to issue sanctions. The Supreme Court vacated the court of appeals’ opinion and reversed, holding (1) the trial court lacked the statutory authority to find Townsend in contempt and impose sanctions; and (2) Townsend’s actions did not place her under the trial court’s authority to impose sanctions as an inherent power of the judiciary. View "In re Mental Health Actions for A.S." on Justia Law

Plaintiff's wife died after various physicians failed to diagnose and treat her obstructed bowel. Plaintiff, acting individually and as a personal representative of his wife's estate, filed a medical malpractice complaint against Community Hospitals of Indiana, Inc. (Community). A jury returned a verdict in favor of Plaintiff and awarded damages in the amount of $8.5 million. Community subsequently made an oral motion to reduce the jury awarded to $1.23 million - the cap imposed by the Indiana Medical Malpractice Act (Act). Plaintiff objected to the reduction of the damage award alleging that the cap was unconstitutional and requesting an evidentiary hearing to develop his constitutional challenges. The trial court denied Plaintiff's request and entered judgment in the amount of $1.25 million. The Supreme Court affirmed, holding that Plaintiff forfeited his opportunity to conduct an evidentiary hearing to challenge the constitutionality of the Act. View "Plank v. Cmty. Hosps. of Ind., Inc." on Justia Law

Patients Abby Allen and Walter Moore sought medical treatment at Clarian North Hospital, which was owned by Clarian Health Partners. After Allen, who was uninsured and not covered by Medicare or Medicaid, received services, the hospital billed Allen its "chargemaster" rates in accordance with a contract between Allen and Clarian. Patients' class action complaint alleged breach of contract and sought declaratory judgment that the rates the hospital billed its uninsured patients were unreasonable and unenforceable. The trial court granted Clarian's motion to dismiss for failure to state a claim upon which relief can be granted. The court of appeals reversed, concluding that the issue of reasonableness required resolution by a fact-finder. The Supreme Court vacated the opinion of the court of appeals and affirmed the judgment of the trial court, holding that Patients' agreement to pay the hospital for the medical services they received in the context of a contract they formed with Clarian was not indefinite and referred to Clarian's chargemaster. As a result, the Court could not impute a "reasonable" price term into the contract. View "Allen v. Clarian Health Partners, Inc." on Justia Law

At age four, B.O. was diagnosed with a mild form of cerebral palsy called spastic diplegia. Subsequently, his parents filed a complaint under the Indiana Medical Malpractice Act, claiming that the healthcare providers who attended B.O.'s birth were negligent. Shortly before trial, B.O.'s healthcare providers settled for a sum allowing B.O. to seek excess damages from the Indiana Patients Compensation Fund (PCF). B.O.'s parents then filed a petition for excess damages, after which the PCF disclosed five expert witnesses prepared to testify either that B.O. did not have spastic diplegia or that if he did, it did not result from the conduct of the healthcare providers at his birth. The parents then sought partial summary judgment seeking to limit the issue at trial, which the trial court granted. The Supreme Court affirmed, holding that the PCF was precluded from disputing the existence or cause of B.O.'s claimed injury under Ind. Code 34-18-15-3(5). View "Robertson v. B.O." on Justia Law

After an inspection revealed deplorable health conditions for its residents, an intermediate care facility for the developmentally disabled was decertified for Medicaid reimbursement. As a result, until the State appointed a receiver nine months later, the facility operated without receiving federal or state funds. This case was a common-law claim for expenses the facility laid out in the meantime for the individuals still residing there. The trial court denied the facility restitution for the unpaid months under a theory of quantum meruit, afforded relief under related breach of contract claims, but offset that judgment by the amount the State paid for its receiver. The Supreme Court affirmed the trial court's ultimate judgment, which resulted in neither party taking anything from the action, holding (1) the facility exhausted its administrative remedies; (2) the facility's quantum meruit claim failed; and (3) the state was entitled to set off the amount owed to the facility on the breach of contract claim against the amount the State paid in operating the receivership of the facility and which the facility then owed. View "Woodruff ex rel. Legacy Healthcare, Inc. v. Ind. Family & Social Servs. Admin." on Justia Law