Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court denying ResCare Health Service's request for a declaratory judgment, holding that ResCare sufficiently pleaded its declaratory judgment request.ResCare, which operates intermediate care facilities in Indiana for individuals with intellectual disabilities, petitioned for administrative reconsideration after an auditor with the Indiana Family & Social Services Administration’s Office of Medicaid Policy and Planning (FSSA) adjusted cost reports to prevent ResCare from recovering costs for over-the-counter medicines under Medicaid. An ALJ granted summary judgment for ResCare. The trial court affirmed the agency's final decision. The Supreme Court reversed, holding (1) ResCare did not need to file a separate complaint for a declaratory judgment; (2) ResCare sufficiently pleaded its declaratory judgment claim; and (3) ResCare's patients did not have to be joined to the litigation before the declaratory judgment request could be considered. View "ResCare Health Services Inc. v. Indiana Family & Social Services Administration" 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

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

Rebecca Kays was convicted of misdemeanor battery and sentenced to 180 days in jail, suspended to twelve months probation. The trial court ordered as a term of probation that Kays pay restitution in the amount of $1,496. Kays appealed, arguing that the trial court improperly ordered restitution as a term of probation because her only source of income was social security disability benefits. The court of appeals reversed, holding that restitution may not be based on social security income, and therefore, the trial court could not take into account Kays' social security income in determining her ability to pay. The Supreme Court granted transfer, thereby vacating the court of appeals, and reversed the trial court. The Court held that social security benefits may be considered by a trial court in determining a defendant's ability to pay restitution, but the trial court erred in failing to determine Kays' ability to pay restitution and to determine her manner of payment. View "Kays v. State" 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