Justia Indiana Supreme Court Opinion Summaries

This petition for post-conviction relief followed Defendant Roy Ward's second trial during which he pled guilty to the 2001 rape and murder of a fifteen-year-old. Ward was sentenced to death following a penalty-phase jury trial. The Supreme Court affirmed Ward's sentence on direct appeal. Ward subsequently sought to have his death sentence set aside by filing a petition for post-conviction relief, in which he raised a number of issues. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) any deficiencies in trial counsel's performance in their mitigation investigation and presentation did not prejudice Ward's defense; (2) trial counsel w343 not ineffective in failing to challenge certain aspects of the State's case; (3) appellate counsel rendered competent, constitutionally adequate representation; (4) trial counsel did not render ineffective assistance under U.S. v. Cronic; (5) Indiana's death penalty statute comports with the state and federal Constitutions; and (6) Ward's claim under Napue v. Illinois was waived. View "Ward v. State" on Justia Law

In this case the Supreme Court examined whether income received by a corporation's affiliated foreign reinsurance companies falls within the ambit of Indiana's gross premium privilege tax statute and is on that basis exempt from Indiana adjusted gross income tax. The corporation in this case was UPS, which protested the Indiana Department of Revenue's audit, which disallowed the exclusion from Indiana adjusted gross income the income of UPS's affiliates. The Indiana tax court granted UPS's motion for summary judgment, reasoning that because UPS was "subject to" the premium tax, it was exempt from the adjusted gross income tax. The Supreme Court reversed, holding that because the record did not establish that during the years in question UPS's affiliates were doing business within the state of Indiana, which was a necessary condition in order to be "subject to" the premium tax, UPS failed in its burden of establishing that it was entitled to summary judgment as a matter of law. Remanded. View "Ind. Dep't of Revenue v. UPS" on Justia Law

Defendant was charged with felony attempted murder. After a bench trial, the trial court rejected Defendant's insanity defense, finding that Defendant's behavior was the result of his voluntary abuse of alcohol. The trial court then found Berry guilty as charged. The court of appeals reversed, concluding that Defendant suffered from "settled insanity," a mental disease or defect caused by Defendant's prolonged and chronic abuse of alcohol, which rendered him unable to appreciate the wrongfulness of his conduct. The Supreme Court granted transfer and affirmed the trial court, holding (1) there was credible expert testimony that Defendant's behavior was caused by the voluntary abuse of alcohol and not a mental disease or defect as defined in Indiana's insanity statute; and (2) accordingly, under the applicable standard of review, the trial court properly rejected Defendant's insanity defense. View "Berry v. State" on Justia Law

Defendant Tina Whiting was charged with murder and robbery. During voir dire, a prospective juror stated that he could not be fair because she knew Defendant, Defendant's grandmother, the victim's family, and the attorneys. The trial judge denied a joint challenge for cause. Defendant did not strike the juror with any of her available peremptory challenges, and the juror served on the jury. Defendant was subsequently convicted of felony murder and felony robbery resulting in serious bodily injury. Defendant appealed, claiming, among other things, that the trial court erred in denying the challenge for cause because Defendant had not exhausted her peremptory challenges. The court of appeals affirmed. The Supreme Court vacated the court of appeals and affirmed Defendant's conviction for felony murder, holding (1) Defendant's claim of error regarding the denial of the challenge for cause was procedurally defaulted, and thus unavailable for review, because Defendant failed to exhaust her peremptory challenges; and (2) Defendant's claim was not reviewable for fundamental error. View "Whiting v. State" on Justia Law

The State charged Defendant Michael Baker with burglary of a structure used for religious worship with the intent to commit theft, a class B felony in connection with an apparent breaking and entering of a church from which nothing had been removed. Defendant was subsequently convicted of class B burglary. The court of appeals reversed Defendant's conviction, concluding that there was insufficient evidence of Defendant's intent to commit theft within the church. The Supreme Court granted transfer and affirmed the judgment of conviction, holding that a reasonable jury could have found beyond a reasonable doubt that Defendant committed breaking and entering of the church with the intent to commit theft. View "Baker v. State" on Justia Law

In this case, the State filed charges against Defendant, and after a brief period of incarceration, Defendant was released. Shortly after his release, Defendant was again incarcerated but on a probation-revocation case. While he was incarcerated on the probation-revocation case, Defendant filed a Ind. R. Crim. P. 4(B) motion requesting a speedy trial on the pending charges. The trial court denied the motion. The Supreme Court affirmed, holding (1) Rule 4(B) is available to a defendant only when the defendant is held on the pending charges for which he requests a speedy trial; and (2) accordingly, Rule 4(B) was not available to Defendant on the pending charges for which he sought a speedy trial because he was not incarcerated on those charges. View "Cundiff v. State" on Justia Law

Brice Webb was charged with murder in the shooting death of his girlfriend. Webb requested a jury instruction on the lesser offense of reckless homicide. The trial court denied the request and Webb was convicted as charged. The Supreme Court reversed Webb's conviction and remanded the cause for a new trial, holding that the trial court's refusal to instruct the jury on the lesser-included offense of reckless homicide was reversible error, as the evidence in this case produced a serious evidentiary dispute concerning Webb's state of mind, and whether Webb acted knowingly or recklessly, that would justify giving the requested instruction. View "Webb v. State" on Justia Law

The trial court revoked the probation of Troy Smith for failure to pay weekly child support as a condition of his probation. On appeal, Smith argued that the State failed to carry its burden of proof that his failure to pay was reckless, knowing, or intentional. The Supreme Court affirmed the judgment of the trial court, holding (1) it is the defendant probationer's burden to show facts related to an inability to pay and indicating sufficient bona fide efforts to pay so as to persuade the trial court that further imprisonment should not be ordered; and (2) here, Smith failed to carry his burden, and therefore, the trial court did not abuse its discretion in revoking Smith's probation. View "Smith v. State" on Justia Law

The Indiana Department of Environmental Management (IDEM) informed Flexdar, Inc. that Flexdar would be liable for the costs of cleaning up trichloroethylene (TCE) contamination on a site where Flexdar previously had operations. State Automobile Mutual Insurance Company (State Auto), with whom Flexdar maintained general liability and umbrella insurance policies for the period when the contamination occurred, filed a declaratory judgment action, contending that coverage for the TCE contamination was excluded pursuant to a pollution exclusion in the policies. The trial court entered summary judgment in favor of Flexdar, concluding that the language of State Auto's pollution exclusion was ambiguous and therefore should be construed against State Auto and in favor of coverage. The Supreme Court affirmed, holding that the language of the pollution exclusion at issue was ambiguous, and therefore, in accordance with precedent, the policies were construed in favor of coverage. View "State Auto. Mut. Ins. Co. v. Flexdar, Inc." on Justia Law

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services. View "Perdue v. Gargano" on Justia Law