Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the trial court, after a hearing, finding B.N. to be severely disabled and to be in need of extended custody, care, and treatment, holding that the trial court abused its discretion, but the error was harmless.B.N. requested to appear at her commitment hearing in person, but the trial court denied the request, stating, "we're proceeding remotely due to the COVID-19 pandemic." On appeal, B.N. argued that the trial court's denial of her request for in-person hearing violated Administrative Rule 14 and constitutional and statutory provisions. The Supreme Court affirmed, holding (1) the trial court did not make the requisite findings of good cause to conduct B.N.'s commitment hearing virtually; but (2) the trial court's error was harmless. View "In re Civil Commitment of B.N." on Justia Law

The Supreme Court affirmed Defendant's convictions for murder and two counts of attempted murder, holding that the jury permissibly resolved the issues of fact raised on appeal against Defendant.On appeal, Defendant argued that the evidence did not support his convictions because the jury could not have found beyond a reasonable doubt that he was the shooter at issue. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to identify Defendant as the shooter; (2) the doubts Defendant raised about the evidence presented factual disputes that the jury was entitled to resolve; and (3) the jury could reasonably have resolved an inconsistency in the evidence in the State's favor. View "Young v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing this action under Indiana Trial Rule 12(B)(6) but modified the judgment to reflect that the dismissal was without prejudice, holding that the church-autonomy doctrine applied in this case and required its dismissal under Rule 12(B)(6).Plaintiff sued the Roman Catholic Archdiocese of Indianapolis, Inc., asserting intentional interference with his contract and employment with Cathedral High School. The Archdiocese moved to the dismiss the complaint and invoked three defenses under the First Amendment, including the church-autonomy defense. The trial court dismissed the case with prejudice for failure to state a claim and for lack of subject-matter jurisdiction. The Supreme Court affirmed, holding that dismissal under Rule 12(B)(1) was improper but that the church-autonomy doctrine barred Plaintiff's claims. View "Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis, Inc." on Justia Law

The Supreme Court reversed Defendant's convictions for several drug-related offenses, holding that the trial court abused its discretion by admitting evidence obtained during a search of Defendant's home.Officer Cody Scott was investigating a robbery when he detained Defendant for an outstanding warrant for his arrest. The officer asked Defendant if he would escort him inside the house, and Defendant agreed to the request. After Officer Scott observed possible narcotics in the residence he obtained a search warrant, the execution of which revealed various drug paraphernalia. The court of appeals affirmed Defendant's convictions, holding that the trial court did not abuse its discretion by denying Defendant's motion to suppress. The Supreme Court reversed, holding that Defendant's protections under Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), were violated in this case, and therefore, the trial court abused its discretion by admitting evidence obtained during the search. View "McCoy v. State" on Justia Law

The Supreme Court reversed the the order of the trial court granting summary judgment in favor of the Gary Housing Authority and dismissing allegations that the Housing Authority's notice of its administrative taking of 624 Broadway, LLC's property was constitutionally deficient, holding that the deficient notice was not harmless.The Housing Authority only provided notice of its taking of 624 Broadway's property by publication, despite knowing how to contact the LLC. After 624 Broadway unsuccessfully requested the Housing Authority to postpone the meeting to its appraiser could assess the property 624 Broadway brought this complaint, alleging that the Housing Authority violated its federal due process rights. The trial court granted summary judgment for the Housing Authority. The Supreme Court reversed, holding (1) the Housing Authority's constitutionally deficient notice to 624 Broadway was prejudicial; and (2) 624 Broadway was entitled to a damages hearing. View "624 Broadway, LLC v. Gary Housing Authority" on Justia Law

The Supreme Court overruled State ex rel. Keaton v. Circuit Court of Rush County, 475 N.E.2d 1146 (Ind. 1985), which held that criminal trial courts do not have inherent authority to require the State to produce complete copies of police reports over the prosecuting attorney's timely work product objection, holding that Trial Rule 26(B)(3) supersedes Keaton.In making its holding in Keaton the Supreme Court cited an undue burden on prosecuting attorneys and the potential for abuse by defense counsel. Noting that the majority of prosecutors across the State regularly produce police reports to defendants while the minority automatically assert the work product privilege over those documents the Supreme Court reconsidered its decision in Keaton. The Court then overruled Keaton, holding (1) the decision in Keaton conflicts with Indiana's liberal discovery rules, including Trial Rule 26(B)(3); and (2) the reasons justifying the Court's decision in Keaton are improper considerations in a work product analysis and unsupported in today's modern age. View "Minges v. State" on Justia Law

The Supreme Court dismissed this action in which Plaintiffs challenged the City of Gary's local ordinance designed to protect the rights of immigrants, holding that Plaintiffs lacked standing to bring this action.Plaintiffs, four Indiana residents, challenged the "welcoming ordinance" adopted by Gary in 2017 establishing its commitment to protecting the rights of immigrants, seeking a declaration that four sections of the ordinance violated Ind. Code 5-2-18.2 and enjoining the city from enforcing those sections. The trial court entered summary judgment for Plaintiffs. The Supreme Court remanded the case to the trial court with instructions to dismiss the action for lack of standing, holding that where Plaintiffs alleged no injury but instead argued that neither statutory nor public standing requires an injury, Plaintiffs did not meet constitutional requirements for conferring standing. View "City Of Gary v. Nicholson" on Justia Law

In this interlocutory appeal the Supreme Court declined to adopt the apex doctrine, which can prevent parties from deposing top-level corporate executives absent the requesting party making certain initial showings, holding that remand was required for the trial court to consider a motion for a protective order with the benefit of guidance set forth in this opinion.Plaintiffs sued the National Collegiate Athletic Association (NCAA) alleging that despite being aware of the consequences of repetitive head trauma, the NCAA failed to implement reasonable concussion-management protocols to protect its athletes, causing three former college football players to die from a neurodegenerative disease linked to repetitive head trauma. The NCAA moved twice for a protective order to prevent Plaintiffs from deposing three of its high-ranking executives. After the trial court denied the motions the NCAA sought discretionary interlocutory review, inviting the Supreme Court to adopt the apex doctrine. The Supreme Court remanded the case, holding (1) this appeal was properly before the Court; and (2) although the Court declines to adopt the apex doctrine, it establishes a framework that harmonizes its principles with the applicable trial rules to aid courts in determining whether good cause exists to prohibit or limit the deposition of a top-level official in a large organization. View "National Collegiate Athletic Ass'n v. Finnerty" on Justia Law

The Supreme Court affirmed Defendant's convictions of six offenses, including unlawful possession of a firearm by a serious violent felon in violation of Ind. Code 35-50-2-8, holding that none of Defendant's allegations of error required reversal.On appeal, Defendant argued that the trial court erred in giving Preliminary Instruction 18, and that the error was fundamental. The court of appeals agreed and reversed. The Supreme Court granted transfer and affirmed, holding (1) Defendant invited any error that arose from Preliminary Instruction 18, which precluded relief on direct appeal; (2) the traffic stop leading to Defendant's arrest did not violate the Fourth Amendment; and (3) Defendant waived his last allegation of error. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court declining to allow Defendant, who was charged with several counts of child molesting, from deposing the child victim under the recently-enacted Ind. Code 35-40-5-11.5, which restricts the statutory right of criminal defendants accused of sexual offenses against children to depose prosecution witnesses, holding that there was no error.In 2020, the State charged Defendant with several counts of child molesting. Before Defendant sought to depose the child victim section 35-40-5-11.5 took effect. The trial court denied Defendant's ensuing motion to depose the child under the statute. The court of appeals reversed, concluding that the statute impermissibly conflicted with the Indiana Trial Rules governing the conduct of depositions. The Supreme Court granted transfer and affirmed, holding (1) the statute was not being retroactively applied to Defendant; (2) the statute was not a procedural statute that could conflict with the Trial Rules and it did not violate constitutional separation of powers provisions; and (3) the statute did not violate any of Defendant's state or federal constitutional rights. View "Church v. State" on Justia Law