Justia Indiana Supreme Court Opinion Summaries

Bedford Recycling, Inc. applied to the Monroe County Board of Zoning Appeals (BZA) for a conditional use permit to operate a scrap metal collection and sorting facility on property zoned for mineral extraction. The county’s zoning ordinance did not specifically allow scrap metal recycling, so Bedford sought approval under the category of “Central Garbage/Rubbish Collection Facility.” The BZA granted the permit after a public hearing in which Bedford acknowledged the facility would not handle solid waste, a typical requirement for the permit. Subsequently, Republic Services, a neighboring property owner, filed for judicial review, arguing that Bedford’s facility did not meet the ordinance’s requirements. While preparing written findings to support its decision, the BZA’s attorney concluded that granting the permit was a legal error, as Bedford’s proposed use did not fit the permit’s definition.After several meetings and changes in BZA membership, the Board voted to revoke Bedford’s permit, finding that the facility was essentially a scrap yard, which was not a permitted use in the zoning district. Bedford then sought judicial review in the Monroe Circuit Court, which found that the BZA lacked statutory authority to revoke the permit based on a change in reasoning or alleged legal error, and reinstated the permit. The Indiana Court of Appeals reversed, holding that the BZA could correct its own legal error and revoke the permit.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Court held that administrative bodies like the BZA have only the powers expressly granted by statute and possess no inherent or common law authority to reconsider or revoke final decisions absent explicit legislative authorization. The Court disapproved prior appellate decisions that recognized an “error of law” exception. Accordingly, the Supreme Court affirmed the trial court’s order vacating the BZA’s revocation and reinstated Bedford’s conditional use permit. View "Monroe County Board of Zoning Appeals v. Bedford Recycling, Inc." on Justia Law

The petitioners own a home on nearly four acres of land in a gated community in Crown Point, Indiana. For the 2019 tax year, the Lake County Assessor classified one acre of their property as a “homestead” and taxed it at one percent of its assessed value, while the remaining 2.981 acres were taxed as non-residential property at a higher rate. The owners did not dispute the total assessed value but argued that the statutory one-acre limit for the homestead tax cap was unconstitutional as applied to them, claiming that their entire parcel constituted “curtilage” under the Indiana Constitution and should be subject to the lower tax rate.After the Lake County Property Tax Assessment Board of Appeals rejected their claim, the Indiana Board of Tax Review affirmed, stating it lacked authority to declare a statute unconstitutional and was bound by the one-acre limit. The petitioners appealed to the Indiana Tax Court, which reversed the Board’s decision. The Tax Court held that the Constitution does not permit a fixed one-acre limitation for the homestead tax cap and remanded for further proceedings to determine whether the excess acreage was used as part of the principal place of residence.The Indiana Supreme Court reviewed the Tax Court’s decision de novo. It held that, even if the Constitution does not impose a size limit on curtilage, the petitioners failed to present sufficient evidence that their excess land was used as curtilage. Therefore, they did not meet their burden to prove the statute unconstitutional as applied to them. The Supreme Court reversed the Tax Court’s judgment and remanded with instructions to affirm the Board’s determination in favor of the Assessor. View "Sawlani v. Lake County Assessor" on Justia Law

EdgeRock Development, LLC developed a planned unit development in Westfield, Indiana, comprising retail and residential projects. EdgeRock contracted with C.H. Garmong & Son, Inc. and Fox Contractors Corp. to develop the lots. When EdgeRock fell behind on payments, Garmong and Fox recorded construction liens on all five lots, including those sold to ZPS Westfield, LLC and a nonparty. The contractors sued EdgeRock for breach of contract and sought to foreclose the liens.The Hamilton Superior Court awarded the contractors most of the relief they sought, including foreclosure of the construction liens. The Indiana Court of Appeals reversed the foreclosure, concluding the liens were overstated as they were not limited to debts for improvements directly benefiting the properties to which the liens attached.The Indiana Supreme Court reviewed the case to address the validity and scope of the construction liens and the priority between the construction liens and First Bank Richmond’s mortgage lien. The court held that a construction lien secures only the debt for improvements directly benefiting the property to which the lien attaches. Therefore, the contractors can foreclose the liens on each property to recover only those amounts. The court also concluded that First Bank’s mortgage lien is senior to the construction liens for the amount loaned to satisfy Garmong’s prior construction lien but junior for the remaining amounts.The court affirmed the trial court’s judgment in part, reversed in part, and remanded for the trial court to amend the judgment consistent with its opinion. The court also noted that its holdings do not disturb the in personam judgments against EdgeRock on Garmong’s and Fox’s breach-of-contract claims. View "Edgerock Development, LLC v. C.H. Garmong & Son Inc" on Justia Law

Diamond Quality, Inc., an industrial inspection and sorting company, had been working with subsidiaries of Dana Incorporated, including Dana Light Axle Products, LLC (Dana Fort Wayne). In 2019, Dana Fort Wayne stopped using Diamond's services. In 2020, Dana Fort Wayne twice refused Diamond entry onto its premises to sort defective parts, despite requests from other Dana subsidiaries in Mexico.Diamond sued Dana Fort Wayne in Allen County state court, alleging tortious interference with its business relationships and contracts with the Dana subsidiaries in Mexico. Dana Fort Wayne removed the case to the United States District Court for the Northern District of Indiana, where it denied the allegations and moved for summary judgment, arguing that barring Diamond from its premises was not tortious.The district court sought guidance from the Indiana Supreme Court on whether a corporate subsidiary can tortiously interfere with the contracts and business relationships of another subsidiary of the same parent company. The Indiana Supreme Court reframed the question to whether a property owner acts without justification, for purposes of a claim for tortious interference, when barring a plaintiff from accessing the property.The Indiana Supreme Court held that a property owner is always justified in excluding another from its premises absent a contractual or statutory duty. This right to exclude is fundamental to property law and cannot support a claim for tortious interference under Indiana law. The court did not need to choose between the second and third restatements of torts for this decision. The answer to the reframed certified question was "no." View "Diamond Quality, Inc. v. Dana Light Axle Products, LLC" on Justia Law

The plaintiffs, Hari and Saranya Nagireddy, live next to a property owned by Willow Haven on 106th Street, LLC, which is being developed to house up to ten residents with Alzheimer’s disease and dementia. After Willow Haven obtained a building permit from Carmel, the Nagireddys sued, seeking a declaration that the proposed use would be a public nuisance as it would violate Carmel’s unified development ordinance (UDO). They also obtained a preliminary injunction against further construction.The Hamilton Superior Court denied Willow Haven’s motion to dismiss and issued a preliminary injunction, finding that the Nagireddys did not need to exhaust administrative remedies before the Board of Zoning Appeals (BZA) and were likely to succeed on their claim. The Indiana Court of Appeals affirmed the trial court’s decision, with a majority holding that the Nagireddys were not required to exhaust administrative remedies and were likely to succeed on their nuisance claim. A dissenting judge argued that the UDO was ambiguous and should be interpreted to permit Willow Haven’s land use.The Indiana Supreme Court reviewed the case and held that the preliminary injunction was improper. The court found that the Nagireddys did not prove they were likely to win their public-nuisance claim, as they did not show that Willow Haven’s proposed land use violated the UDO at this preliminary stage. The court noted that the UDO incorporates state and federal law, which may protect Willow Haven’s land use. The court reversed the trial court’s decision, vacated the injunction, and remanded the case for further proceedings. View "Willow Haven on 106th St, LLC v. Nagireddy" on Justia Law

Gerard A. Kirsch, a member of Calvary Temple Church of Evansville, Inc., was injured while building a storage barn on the church's property. Kirsch fell from a ladder and sustained a severe arm injury. He sued the church, alleging negligence for failing to provide safe equipment and proper supervision.The Vanderburgh Superior Court denied the church's motion for summary judgment, which argued that Indiana Code section 34-31-7-2 limited the church's liability. The court held that a jury must decide if the church breached any duty to Kirsch. The Indiana Court of Appeals affirmed, interpreting the statute narrowly to apply only to parts of the premises used primarily for worship services, thus allowing Kirsch's claim to proceed.The Indiana Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that the term "premises" in Indiana Code section 34-31-7-2 includes the entire parcel of land owned by the church, not just the areas used primarily for worship services. Since the church's entire property is used primarily for worship services, the statute applies, limiting the church's liability to warning of hidden dangers and refraining from intentional harm. Kirsch admitted the church breached neither duty, leading the court to grant summary judgment in favor of the church. View "Calvary Temple Church of Evansville, Inc. v. Kirsch" on Justia Law

A highway construction project in Johnson County, Indiana, required the widening of State Road 37 and the closure of an intersection at Fairview Road. The State initiated an eminent domain action to acquire a 0.632-acre strip of land from Franciscan Alliance, Inc., and the owners of easement rights over the strip, including The Market Place at State Road 37, LLC, and SCP 2010-C36-018, LLC, contested the action and sought damages due to changes in traffic flow from the intersection closure.The Johnson Superior Court appointed appraisers who valued the land and assessed damages. A jury trial followed, resulting in a verdict awarding $680,000 to Franciscan and $1,500,000 to SCP. The State appealed, arguing that damages for changes in traffic flow were not compensable. The Indiana Court of Appeals reversed the trial court's judgment, holding that the damages awarded were erroneous under existing caselaw on circuity of travel and traffic flow. Franciscan and SCP petitioned for transfer, which the Indiana Supreme Court granted.The Indiana Supreme Court reaffirmed the rule that when a road-improvement project leaves a property’s access points unchanged, a landowner cannot recover damages from changes in traffic flow, as these do not result from the taking of a property right. The Court held that the State’s construction project did not affect the owners’ access points to their properties, and thus, damages from the intersection closure were not compensable. The Court reversed the trial court’s judgment and remanded for proceedings to determine the just compensation owed to Franciscan for the 0.632-acre strip of land. View "State v. Franciscan Alliance, Inc." on Justia Law

In this case decided by the Indiana Supreme Court, plaintiff Dux North LLC, the owner of a landlocked property in rural Hamilton County, Indiana, sought an implied easement over adjacent property owned by defendants Jason and Sarah Morehouse. Dux North claimed either an implied easement by prior use or an implied easement of necessity over the Morehouse property. The court clarified that these two types of implied easements are conceptually different. For an implied easement by prior use, the claimed servitude must predate the severance creating the separate parcels. For an implied easement of necessity, the claimed necessity need to arise only at severance and not before. Thus, Dux North could seek relief under either implied easement, and the failure of one such easement does not necessarily defeat the other. Furthermore, the court held that an implied easement of necessity requires a showing that access to the property by another means is not just impractical but impossible. The court then reversed the trial court's judgment granting Dux North's motion for summary judgment on the easement-by-prior-use claim and denying the Morehouses' motion for partial summary judgment on the easement-of-necessity claim. The case was remanded for further proceedings to decide whether Dux North has an easement by prior use over the Morehouse property. View "Morehouse v. Dux North LLC" on Justia Law

The case revolves around injury suffered by a swimmer, Dr. Jennifer Pennington, who collided with the corner of a swimming-pool wall at a health and fitness center owned and operated by Memorial Hospital of South Bend, doing business as Beacon Health and Fitness. The design and construction of the swimming pool was carried out by Spear Corporation and Panzica Building Corporation. The Penningtons filed a suit against Beacon, Spear, and Panzica, alleging negligent design, failure to warn, negligent maintenance and operation, negligent construction, and deprivation of companionship due to the injury. The trial court granted summary judgment to Panzica and Spear on all counts and to Beacon on some counts, but denied summary judgment to Beacon on the count of negligent maintenance and operation and failure to provide adequate warnings and instructions. The Indiana Supreme Court held that Beacon was not entitled to summary judgment on any count, except as to the single issue of the level of the water within Count III. The court affirmed summary judgment for Spear and Panzica, stating that the Penningtons failed to provide admissible evidence regarding Spear or Panzica's breach of their professional duty of care. However, the court found that there were issues of fact regarding Beacon's role in the pool’s design and its maintenance and operation that required a trial. View "Pennington v. Memorial Hospital of South Bend, Inc." on Justia Law

In this case before the Indiana Supreme Court, Thomas DeCola, the appellant, filed a suit to quiet title after purchasing property owned by Norfolk Southern Corporation, the appellee, at a tax sale. The property had fallen into tax delinquency. DeCola sought judgment on the pleadings, arguing that Norfolk had not received proper notice of the tax sale, the petition for tax deed, or its right of redemption. The trial court converted DeCola's motion into one for summary judgment because it considered evidence outside the pleadings. In its detailed order, the trial court denied DeCola's summary judgment motion, finding the tax deed void due to lack of sufficient notice to Norfolk.DeCola appealed the denial of summary judgment, claiming it was a final order. However, the Indiana Supreme Court held that the trial court's order denying summary judgment was not a final judgment because it did not resolve all claims as to all parties. The Court stated that the order did not meet any of the five definitions of a "final judgment" as laid out in Rule 2(H) of the appellate rules. Therefore, the Court concluded that it did not have jurisdiction to hear the appeal.The Indiana Supreme Court granted transfer, dismissed the appeal for lack of jurisdiction, and remanded the case back to the trial court for further proceedings. View "DeCola v. Norfolk Southern Corporation, Inc." on Justia Law