Justia Indiana Supreme Court Opinion Summaries

Articles Posted in Indiana Supreme Court
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Plaintiffs filed a malpractice claim against Dr. Anthony Miller and Achilles Podiatry Group seeking damages for the alleged injuries they received after surgery. The trial was delayed due to Plaintiffs' inability to secure an expert witness until after the discovery deadline. Plaintiffs subsequently filed a notice of a new expert witness. The trial court excluded Plaintiffs' expert witness for violation of discovery deadlines and then dismissed the case, concluding that Plaintiffs could not establish their case without the witness. The Supreme Court reversed, holding that the witness exclusion was erroneous, and therefore, the granting of Defendants' motion to dismiss was likewise erroneous. View "Wright v. Miller" on Justia Law

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After certain members of the Indiana House of Representatives Democratic Caucus left the state to prevent the formation of a quorum in order to block a vote on impending legislation, House Republicans passed motions to fine the absent legislators. The fines were withheld from the legislators' pay. Plaintiffs brought suit seeking to recover the withheld pay. The trial court concluded that the determination of the fine was outside the court's jurisdiction because the determination of the fine was within the House's "exclusive constitutional authority" but that review of the collection of fines was within the court's jurisdiction. The court then ordered return of the withheld pay and issued an injunction preventing future withholding. The Supreme Court reversed, holding that when, as here, the Indiana Constitution expressly assigns certain functions to the legislative branch without any contrary constitutional limitation or qualification, disputes arising in the exercise of such legislative powers are nonjusticiable, and the doctrine of separation of powers precludes judicial consideration of the claims for relief. Remanded for dismissal of Plaintiffs' claims for lack of justiciability. View "Berry v. Crawford" on Justia Law

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The Indiana Department of Child Services (DCS) petitioned to terminate Mother and Father's parental rights regarding their three children. The trial court granted the petition, concluding that DCS provided clear and convincing evidence that the conditions resulting in the children's continued placement outside of the home would not be remedied and that termination of Mother and Father's parental rights was in the best interests of the children. Mother appealed. The Supreme Court affirmed, holding (1) DCS showed by clear and convincing evidence that the conditions resulting in placement outside Mother's home would not be remedied; and (2) the trial court did not err in concluding that termination of Mother's parental rights was in the children's best interests. View "In re K.T.K." on Justia Law

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After a police officer rear-ended Plaintiff's vehicle, Plaintiff submitted a tort claim notice to the City of Indianapolis. Plaintiff and her husband subsequently filed a complaint against the City and the Indianapolis Metropolitan Police Department, alleging Plaintiff suffered personal injuries as a direct result of the police officer's negligence. The trial court granted summary judgment for Plaintiffs. The City appealed, arguing that Plaintiff's tort claim notice did not substantially comply with the requirements of the Indiana Tort Claims Act because, on the form, Plaintiff stated that she suffered no injuries from the accident. The Supreme Court affirmed, holding (1) Plaintiff's notice complied with the requirements of Ind. Code 48-8001; and (2) although the notice stated "no injuries," the statute as amended no longer requires any statement regarding injuries, and the legislature did not intend to penalize claimants for including information beyond what the statute requires. View "City of Indianapolis v. Buschman" on Justia Law

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Defendant was charged with murder and assisting suicide. Defendant requested to speak to an attorney while in police custody, but the following afternoon, detectives re-read Defendant his Miranda rights, and Defendant confessed his role in his father's death without counsel present. Defendant filed a motion to suppress the incriminating statements he made to the detective in response to police inquiries. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court reversed the denial of Defendant's motion to suppress, holding that the totality of the circumstances involving the content, place, and timing of the communication by the police with Defendant, notwithstanding Defendant's prior invocation of his right to counsel, constituted impermissible questioning or its functional equivalent. Remanded. View "Hartman v. State" on Justia Law

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Relators were magistrates in the Lake Superior Court, Juvenile Division. Respondents were the Lake Superior Court, Lake Circuit Court, and the courts' judges. Relators complained about a decision made by Respondents to allow Judge Nicholas Schiralli to be reassigned from the Superior Court's County Division to its Juvenile Division. Relators filed this action seeking a permanent writ of mandamus and prohibition, arguing that a transfer of the Judge to the Juvenile Division would violate Ind. Code 33-33-45-21(e). Relators requested a permanent writ (1) declaring that Judge Schiralli could not be reassigned to the Juvenile Division; and (2) ruling that no current judge of the Superior Court was eligible for transfer to the Juvenile Division. The Supreme Court granted in part and denied in part the relief sought by Relators, holding (1) section 33-33-45-21(e) prevents Respondents from reassigning, transferring, or rotating Judge Schiralli from the County Division to the Juvenile Division; and (2) but this prohibition did not preclude the Judge from applying to be appointed, under the merit-selection process, to fill a vacancy in the other divisions of the court. View "State ex rel. Commons v. Lake Superior Court" on Justia Law

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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

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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

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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

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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