Justia Indiana Supreme Court Opinion Summaries

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

Plaintiff successfully applied for employment at Labor Works, received job assignments an paychecks, and was never fired or laid off. Plaintiff later filed a class action lawsuit against Labor Works under the Indiana Wage Payment Act seeking to recover unpaid wages. Labor Works moved for summary judgment, arguing that day laborers like Plaintiff were involuntarily separated from the payroll at the end of every shift and thus were required to proceed under the Wage Claims Act. The trial court granted Labor Works's motion and dismissed Plaintiff's claim. The Supreme Court reversed, holding that because Plaintiff had a reasonable expectation of continuing to receive job assignments from Labor Works on the day she filed her claim, she was not separated from the payroll for the purpose of the Wage Claims Act, and therefore, Plaintiff could proceed with her claim under the Wage Payment Act. View "Walczak v. Labor Works - Fort Wayne LLC" on Justia Law

An encounter between a tenured professor at a private university and his department head turned into a formal complaint of harassment against the professor. After extensive internal proceedings, the professor's tenure was rescinded and he was dismissed from the university's faculty. The professor filed suit claiming breach of his employment contract and tenure agreement. The trial court granted summary judgment in favor of the university. The Supreme Court affirmed the decision of the trial court, holding (1) the professor's conduct constituted harassment under the terms of his employment contract such that the university could dismiss him; (2) the university did not deny the professor the procedural entitlements afforded under the professor's employment contract's terms; and (3) the university did not deprive the professor of due process. View "Haegert v. Univ. of Evansville" on Justia Law

Employer allowed Employee to take a college class during his normal work hours but informed him he would have to use his vacation, compensation, or unpaid time rather than take shorter lunches, come in early, or stay later. Employee enrolled in the class but did not follow Employer's instructions and failed properly to account for his time off. Consequently, Employee was fired and denied unemployment benefits. An ALJ overturned that decision and granted Employee unemployment benefits, concluding that the discipline was too severe for only a small amount of misreported time. The review board of the department of workforce development upheld the original denial of unemployment benefits, finding that J.M. was discharged for just cause and thus ineligible for unemployment benefits. The Supreme Court affirmed the review board's denial of benefits, holding that the findings of fact by the review board showed Employee violated his supervisor's instructions and the employee handbook, which were statutory grounds for just-cause discharge. View "J.M. v. Review Bd. of Ind. Dep't of Workforce Dev." on Justia Law

In this case, Plaintiff prevailed on its Access to Public Records Act (Act) claim against a public agency and an intervening private party. As required by statute, the trial court awarded Plaintiff attorney's fees. The fees were awarded against both the public agency and the intervening private party, jointly and severally. The private party argued that the Act does not contemplate the award of attorney's fees against an intervening private party and that only the public agency should be liable for the fees. The Supreme Court affirmed the trial court's award of attorney's fees to Plaintiff, holding (1) the Act, in light of the legislature's liberal-construction mandate and the statute's underlying policy, permits the award of attorney's fees against an intervening private party; and (2) in this case, the trial court did not abuse its discretion in its apportionment of liability. View "Shepherd Props. Co. v. Int'l Union of Painters & Allied Trades" on Justia Law

Stephan Odders and Gerald Kerber were former employees of Loparex, a corporation in the release liner industry. Both employees were subject to a one-year noncompetition agreement upon termination of employment. After ceasing employment at Loparex, both employees began employment with MPI Release Technologies, a competitor in the release liner industry. Loparex sued Kerber and Odders (Defendants) in the U.S. district court, seeking injunctive relief under the Illinois Trade Secrets Act and damages resulting from Defendants' breach of the noncompetition agreement. Defendants filed amended answers and counterclaims accusing Loparex of blacklisting in violation of Indiana law. The Supreme Court accepted certification to answer questions of state law and held (1) Wabash Railroad Co. v. Young, which held that Indiana's Blacklisting Statute did not provide a cause of action to individuals who voluntarily leave their employment, is no longer good law and individuals who voluntarily leave employment are not barred from making a claim under the Blacklisting Statute; (2) attorney fees are not an element of compensatory damages under the Blacklisting Statute; and (3) an employer's suit against a former employee to protect trade secrets is not a basis for recovery under the Blacklisting Statute. View "Loparex, LLC v. MPI Release Techs., LLC" on Justia Law

The City of Kokomo terminated the employment of Mark Thatcher, a police officer, after Thatcher sustained a knee injury in the line of duty. Thatcher was a member of the 1977 Fund, a disability and pension fund for police officers. Thatcher began receiving disability benefits subsequent to his injury. After Thatcher's knee was repaired, he sought reinstatement to active duty. The City decided not to reinstate Thatcher, who was fifty years of age and had completed four years of service in the police department, based on Ind. Code 36-8-4-7(a). Thatcher brought claims in federal district court against the City and Kokomo Police Department (KPD) under the Age Discrimination in Employment Act and Americans with Disabilities Act. The Supreme Court accepted certification and held that the City correctly determined that Thatcher was statutorily prohibited from returning to the KPD, as (1) section 36-8-4-7(a) applies to a member of the 1977 Fund who is receiving disability benefits and who has been determined to have been recovered; and (2) the time period during which a person receives disability benefits does not count toward "years of service" as that term is used in section 36-8-4-7(a). View "Thatcher v. City of Kokomo " on Justia Law

For over twenty-five years, the State required certain employees to work forty-hour weeks while requiring other employees to work only 37.5-hour weeks. Through the employees received the same biweekly paycheck, the effect of the State's policy was a disparity in actual hourly wage. The State ended the policy in 1993, but this class action was brought on behalf of those forty-hour employees. The court of appeals found (1) the merit employees were owed back pay on their statute-base claims from the day they filed their complaint or grievances until the day the State eliminated its split-pay system; and (2) the non-merit employees were owed back pay on their constitutional claims from the day the State eliminated its split-pay system and extending back approximately twenty years. The Supreme Court affirmed in part and reversed in part, holding that, under the doctrine of laches, the back pay recovery of the non-merit employees should be limited in the same manner as the court of appeals set forth for that of the merit employees. View "Richmond State Hosp. v. Brattain" on Justia Law

In 2008, Chrysler offered a buyout program to employees in Kokomo, Indiana. Those employees then applied for unemployment benefits under Indiana's Unemployment Compensation Act. The Indiana Department of Workforce Development denied the claims. The Review Board of the Indiana Department of Workforce Development ultimately awarded benefits under a narrow provision of the Act. The court of appeals reversed, holding that the Board's application of the provision was erroneous and inconsistent with the statute. The Supreme Court granted transfer and vacated the court of appeals. The Court then affirmed the decision of the Board, holding that the Board properly applied the law to its findings of fact, and the Board's conclusion that the employees were eligible for benefits was reasonable in light of the evidence before it. View "Chrysler Group, LLC v. Review Bd. of the Dep't of Workforce Dev." on Justia Law

After Employee was unable to successfully complete her necessary training, Employer gave her the option to resign immediately or to be placed on a thirty-day unpaid leave of absence. Employee opted to resign immediately and thereafter sought unemployment insurance benefits. The Department of Workforce Development denied Employee's application for benefits on the grounds the Employee voluntarily left employment and did so without good cause. An ALJ concluded (1) Employee did not voluntarily quit her position but was constructively discharged, and (2) Employee was disqualified from receiving benefits because she had breached a duty reasonably owed to her employer, which breach constituted just cause for her termination. The Unemployment Insurance Review Board adopted and approved the ALJ's decision. The Supreme Court affirmed the denial of Employee's claim, holding (1) the Board's finding that Employee breached a duty reasonably owed to Employer was reasonable; and (2) it was reasonable for the Board to find that Employee was discharged for just cause and was therefore ineligible for benefits. View "Recker v. Ind. Dep't of Workforce Dev. Review Bd." on Justia Law