Justia Indiana Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court against the State on the State's delinquency petition that it filed against Anthony Neukam, holding that neither the juvenile court nor the circuit court had jurisdiction in this case.Neukam allegedly molested his young cousin both before and after he was eighteen. When Nuekam was twenty, the State brought charges against him in criminal court. When Neukam was twenty-two, the State filed a delinquency petition in juvenile court for acts Neukam allegedly committed before turning eighteen. Thereafter, the Supreme Court decided that juvenile courts lack jurisdiction over delinquency petitions once the accused is age twenty-one. The State then dismissed the juvenile case and moved to amend the criminal case to add counts of child molesting Neukam allegedly committed before he was eighteen. The trial court denied the motion. The court of appeals affirmed, concluding that courts lack jurisdiction when an individual is alleged to have committed a delinquent act before turning eighteen but is over twenty-one when the State files charges. The Supreme Court granted transfer and affirmed, holding that no court had jurisdiction over the charges arising from arising from Neukam's alleged misconduct before his eighteenth birthday. View "State v. Neukam" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting summary judgment for Illinois Casualty Company in this declaratory judgment action, holding that a liquor liability exclusion in the relevant policy absolved Illinois Casualty of a duty to defend or indemnify its insured under its general business owners' policy.Illinois Casualty insured Big Daddy's Show Club. Third-parties filed a lawsuit against Big Daddy's and related entities (collectively, Parks defendants) claiming that Big Daddy's violated Indiana's Dram Shop Act, Ind. Code 7.1-5-10-15.5. Illinois Casualty field a separate declaratory judgment action seeking a declaration that it did not owe a duty to defend or indemnify the Parks defendants in the underlying lawsuit. The trial court granted summary judgment for Illinois Casualty. The Supreme Court affirmed, holding that Illinois Casualty did not owe a duty to defend or indemnify the Parks defendants under the relevant policies. View "Parks v. Illinois Casualty Co." on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Seneca Mortgage Services after finding that Neal Bruder breached the parties' consulting agreement by failing to pay the consultant's fee, holding that there was no error.The court of appeals reversed the judgment of the trial court, finding that Seneca's recovery of the fee would sanction the requirement of an illegal act as a condition of the loan Seneca obtained to Bruder. The Supreme Court granted transfer, vacated the court of appeals' opinion, and affirmed the trial court's judgment, holding (1) the record lacked support for the conclusion that Bruder was required, or even asked, to commit an illegal act; and (2) the parties' agreement provided for the consultant's fee to be paid regardless of whether a particular financing offer was accepted. View "Bruder v. Seneca Mortgage Services, LLC" on Justia Law

The Supreme Court affirmed the judgment of a panel of the court of appeals dismissing an appeal in this temporary commitment case on the grounds that the appeal was moot, holding that "public interest exception" to mootness applied.After a hearing, the trial court found E.F. was gravely disabled and entered a temporary commitment order allowing for her emergency detention. While E.F.'s appeal was pending, the commitment order expired. The court of appeals dismissed E.F.'s appeal as moot, interpreting T.W. v. St. Vincent Hospital & Healthcare Center, Inc., 121 N.E.3d 1039 (Ind. 2019), as disfavoring the practice of applying the public interest exception except in "rare circumstances." The Supreme Court reversed, holding that E.F. should have the opportunity to make certain arguments before the court of appeals. View "In re Commitment of E.F." on Justia Law