Justia Indiana Supreme Court Opinion Summaries

After a shooting that occurred at a bar, Plaintiffs filed a complaint against the bar alleging negligence. The trial court entered summary judgment in favor of the bar, concluding that the shooter’s criminal acts were unforeseeable, and therefore, the bar had no duty to anticipate and take steps to prevent the shooter’s conduct. The court of appeals reversed, declaring that reasonable foreseeability was not part of the analysis with respect to the bar’s duty. The Supreme Court granted transfer and affirmed the judgment of the trial court, holding (1) the trial court in this case employed a now-discarded analytical tool in determining the question of foreseeability; (2) in a negligence action, where foreseeability is an element of duty, this necessarily means the court must determine the question of foreseeability as a matter of law and must engage in a general analysis of the broad type of plaintiff and harm involved without regard to the facts of the actual occurrence; and (3) the trial court properly granted summary judgment in the bar’s favor because a shooting inside a neighborhood bar is not foreseeable as a matter of law. View "Goodwin v. Yeakle's Sports Bar & Grill, Inc" on Justia Law

Defendant negligently struck Plaintiff’s vehicle, causing Plaintiff injuries that required medical treatment. Defendant admitted she was liable for the accident but contested the reasonable value of Plaintiff’s medical care. Before a trial on damages, Plaintiff moved to prevent the jury from hearing evidence that her providers accepted a reduced amount as payment in full. The trial court concluded that the payments were not permitted by Stanley v. Walker, in which the Supreme Court interpreted Indiana’s collateral-source statute to permit a defendant in a personal-injury suit to introduce discounted reimbursements negotiated between the plaintiff’s medical providers and his or her private health insurer, so long as insurance is not referenced. The Supreme Court reversed, holding (1) the rationale of Stanley v. Walker applies equally to reimbursements by government payers; and (2) the trial court misinterpreted Stanley by holding that the collateral-source statute required the exclusion of accepted reimbursements from government payers. Remanded. View "Patchett v. Lee" on Justia Law

Mother informed the Department of Child Services (DCS) that her son (Son) had been molested by her twelve-year-old nephew (Nephew). During a subsequent investigation, Nephew admitted to inappropriately touching Son and one of Mother's daughters (Daughter). Mother, however, was not informed of Nephew's molestation of Daughter. Nephew was adjudicated delinquent and placed on probation, but Mother was not informed of Nephew's adjudication. Mother was later informed of Nephew's admission to the molestation of Daughter from a third party. Mother and Father (Plaintiffs) filed suit against DCS and the Evansville Police Department (EPD), alleging negligence. The trial court granted summary judgment to all defendants on grounds of immunity. The Supreme Court (1) affirmed summary judgment in favor of EPD, holding that EPD was immune from Plaintiffs' claims under the Indiana Tort Claims Act (Act); but (2) reversed the grant of summary judgment in favor of DCS, concluding that it was not immune under either the Act or the child abuse reporting statute. Remanded.View "F.D. v. Ind. Dep't of Child Servs." on Justia Law

In 2005, Plaintiff was robbed and murdered inside his room in a motel owned by Defendant. Joseph Pryor confessed to robbing and killing Plaintiff and was sentenced to eighty-five years in prison for these crimes. In 2007, Plaintiff's estate filed a complaint against Defendant, alleging that Defendant breached his duty to Plaintiff to maintain the motel in a reasonably safe manner. The jury apportioned the fault for Plaintiff's death as follows: one percent to Plaintiff, two percent to Defendant, and ninety-seven percent to Pryor. The Estate subsequently filed a motion to correct error and for a new trial. The trial court ordered a new trial limited to the issue of fault allocation but summarily denied the remainder of the Estate's motion, including the trial court's alleged errors of permitting the jury to allocate fault to Pryor and rejecting the Estate's tendered instruction that would have informed the jurors they could find Defendant liable for Pryor's criminal act. The Supreme Court affirmed, holding that the trial court did not err in permitting the jury to allocate fault to Pryor and in refusing the Estate's tendered instruction that would have permitted the jury to hold Defendant liable for Pryor's intentional act.View "Santelli v. Rahmatullah" on Justia Law

Plaintiff suffered injuries in a collision with Jolene Wright, who was employed by South Central Community Action Program, Inc. Plaintiff and South Central's liability insurer attempted to settle, but settlement efforts failed. Plaintiff later sued Wright and South Central for personal injury damages. Defendants asserted the affirmative defense that South Central was a political subdivision subject to the Indiana Tort Claims Act (ITCA) and that Plaintiff failed to comply with the ITCA notice requirement. The trial court granted summary judgment in Defendants' favor. Plaintiff appealed, citing several reasons to excuse his failure to comply with the notice requirements of the ITCA, including waiver, substantial compliance, agency, and estoppel. The Supreme Court reversed, holding that genuine issues of material fact remained as to whether South Central should be estopped from asserting its ITCA notice defense. Remanded.View "Schoettmer v. Wright" on Justia Law