Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction of one count of felony child molestation, holding that the trial court denied Defendant's requests for a continuance.An impermissible local rule and an improperly issued protective order prevented Defendant's defense attorney from obtaining a copy of the alleged victim's interview. Further, the trial court denied Defendant's requests for a continuance when the state disclosed extensive new evidence the day before trial in order to investigate the new allegations and reconstruct trial strategy. The Supreme Court reversed, holding that the trial court (1) erred in prohibiting Defendant from obtaining a copy of the interview before trial, but reversal was not required on this basis; and (2) abused its discretion by denying Defendant's continuance request, and the error was prejudicial. View "Ramirez v. State" on Justia Law

In this case where an employee of a health-care provider improperly accessed and disclosed information from numerous patients' medical records the Supreme Court held that the health-care provider was not liable.Plaintiffs sued Community and its employee, Katrina Gray, bringing claims of respondent superior and negligent training, supervision and retention claims against Community and claims of negligence and invasion of privacy against Gray. Community filed a motion to dismiss for lack of subject matter jurisdiction and a motion for summary judgment, arguing that Indiana's Medical Malpractice Act (MMA) applied to Plaintiffs' claims and that Gray's tortious acts were committed outside the scope of her employment. The trial court denied both motions. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court correctly concluded that Plaintiffs' claims were not subject to the MMA; but (2) Community was entitled to summary judgment because it affirmatively negated a required element on each of the claims against it. View "Community Health Network, Inc. v. McKenzie" on Justia Law

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

The Supreme Court affirmed in part and reversed in part the judgment of the trial court in this civil forfeiture action, holding that Appellant's designated evidence regarding the origins of much of his seized cash was sufficient to overcome the State's motion for summary judgment.The Supreme Court reversed the grant of summary judgment in the State's favor regarding $8,923 in cash and remanded this case for further proceedings, holding (1) genuine issues of material fact existed as to whether the seized funds were a part of Appellant's alleged racketeering activity; (2) the Racketeering Forfeiture Statue does not permit a court to release the seized res subject to forfeiture to the defendant to fund a defense in the forfeiture action; and (3) the trial court did not abuse its discretion in denying Appellant's request for appointed counsel, even if exceptional circumstances may have existed. View "Abbott v. State" on Justia Law

The Supreme Court reversed the trial court's grant of summary judgment in favor of Anonymous Defendant 1 - a physician group - in this vicarious liability case, holding that disputed issues of material fact existed, precluding summary judgment.In Sword v. NKC Hospitals, Inc., 417 N.E.2d 142 (Ind. 1999), the Supreme Court adopted the Restatement (Second) of Torts section 429, holding that, through apparent or ostensible agency, a hospital may be held vicariously liable for the tortious conduct of an independent contractor. At issue in the instant case was whether Sword extends its vicarious liability to a physical therapist with whom it had no contractual relationship. The Supreme Court remanded the case, holding (1) the rule articulated in Sword is inapplicable on these facts; (2) under Restatement (Second) of Agency section 267 a medical provider may be held liable for the acts of an apparent agent based on the provider's manifestations of an agency relationship with the apparent agent, which causes a third party to rely on such a relationship; and (3) there existed disputed issues of fact as to whether Anonymous Defendant 1 held out Plaintiff's physical therapist as its apparent agent. View "Wilson v. Anonymous Defendant 1" on Justia Law

In this case considering Sword v. NKC Hospitals, Inc., 417 N.E.2d 142 (Ind. 1999), and the Restatement (Second) of Torts section 429's reasoning and application to a non-hospital diagnostic medical imaging center, the Supreme Court held that Sword and section 429's apparent agency principles apply to non-hospital medical entities that provide patients with health care.In Sword, the Supreme Court adopted section 429 and held that a hospital may be held vicariously liable for the tortious conduct of an independent contractor through apparent or ostensible agency. In the instant case, Plaintiff alleged medical malpractice related to his MRI and imaging care. Marion Open MRI moved for summary judgment, arguing that it was not liable for the actions of the radiologist with whom Marion Open MRI contracted. The trial court granted summary judgment in favor of Marion Open MRI, finding that Indiana's appellate court have applied Sword's apparent agent principles only to hospitals and not to non-hospital medical entities. The Supreme Court reversed, holding that Sword and its apparent agency rules apply to non-hospital medical entities. View "Arrendale v. Orthopaedics Northeast, P.C." on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant did not receive ineffective assistance of counsel at sentencing, holding that Defendant did not receive ineffective assistance of counsel.Defendant was convicted of murdering his brother when Defendant was seventeen years old. Defendant sought post-conviction relief alleging that he received ineffective assistance of counsel at sentencing. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that counsel's performance fell objectively below professional norms or that he was prejudiced by any of counsel's alleged errors. View "Conley v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this marital dissolution case, holding that a trial court need not follow a rigid, technical formula in dividing the marital estate so long as the court expressly considers all marital property and offers sufficient justification to rebut the presumptive equal division.In its final decree, the trial court granted Wife's request for spousal maintenance and awarded Wife fifty-five percent of the "net marital estate." On appeal, both Husband and Wife disputed the trial court's award of spousal maintenance and the distribution of the marital estate. The Supreme Court affirmed, holding (1) there was no error in the trial court's award of spousal maintenance; and (2) there was no error in the court's division of marital property. View "Roetter v. Roetter" on Justia Law

In this dispute arising from a supplier's sale of steel for a project to a fabricator who did not perform any work on the project site, the Supreme Court reversed the order of the trial court granting summary judgment for the site's owner, holding that the trial court did not err.The supplier in this case sued to foreclose on its mechanic's lien against the project site. In granting summary judgment for the site's owner, the trial court concluded that the fabricator's lack of on-site work meant that it was also a supplier, and case law barred supplier-to-supplier liens. The Supreme Court reversed, holding (1) under Indiana's mechanic's lien statute a supplier that furnished materials for the erection of a building, regardless of the recipient, can have a lien on that building and the accompanying land; and (2) because the supplier furnished steel for the project, the supplier could have a lien on the project site. View "Service Steel Warehouse Co., L.P. v. United States Steel Corp." on Justia Law

The Supreme Court reversed a portion of the utility regulatory commission's order that approved in part Duke Energy's request to increase its rates for retail consumers, holding that, absent specific statutory authorization, a utility cannot recoup its past costs adjudicated under a prior rate case by treating the costs as a capitalized asset.In 2020, the commission granted Duke's petition for a rate increase in part permitting Duke to recover about $212 million for coal-ash site closures, remediation, and financing costs, with the bulk of the costs having been incurred from 2015 to 2018. At issue was whether the commission could approve reimbursement for a deferred asset without violating the statutory bar against retroactive ratemaking. The Supreme Court answered in the negative, holding that the commission acted without statutory authority in re-adjudicating expenses already governed by a prior rate order. View "Indiana Office of Utility Consumer Counselor v. Duke Energy Indiana, LLC" on Justia Law