Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying a petition for judicial review of the finding of the Indiana Education Employment Relations Board that four Teachers Associations and their respective school corporations violated Indiana law when they collectively bargained over various ancillary duties, holding that there was no error.The Board found the parties bargained over impermissible subjects and curtailed the school's unfettered authority to direct teachers' performance of these various ancillary duties, such as supervising detention, in violation of Ind. Code 20-29-6-4. The trial court found the Board's interpretation of section 20-29-6-4 to be reasonable and denied the Teachers Associations' petition for judicial review. The Supreme Court affirmed, holding that the trial court correctly denied judicial review. View "Culver Community Teachers Ass'n v. Indiana Education Employment Relations Board" on Justia Law

The Supreme Court affirmed Defendant's conviction of involuntary manslaughter as a lesser included offense of voluntary manslaughter, holding that the district court did not err in instructing the jury on involuntary manslaughter.The State charged Defendant with voluntary manslaughter as a Class A felony for the fatal shooting of his wife. During trial, the State formally tendered an instruction on the lesser included offense of involuntary manslaughter based on a battery. The court gave the instruction, and the jury found Defendant guilty of involuntary manslaughter. The Supreme Court affirmed, holding (1) the trial court appropriately instructed the jury on involuntary manslaughter; (2) the State presented sufficient evidence to overcome Defendant's self-defense claim; (3) the trial court did not abuse its discretion by denying Defendant's motion to dismiss for prosecutorial misconduct; and (4) the trial court did not abuse its discretion by treating a handgun as an aggravator. View "Larkin v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress on the grounds that the affidavit supporting the search warrant failed to specify the deputies' "training and experience" in detecting the odor of raw marijuana, holding that the trial court did not err.Defendant was charged with dealing in marijuana and possession of marijuana. Defendant filed a motion to suppress, arguing that the search violated his constitutional rights because the affidavit failed to specify the deputies' training and experience in detecting a specific smell. The trial court denied the motion to suppress. The Supreme Court affirmed, holding, as an issue of first impression, that trained and experienced law enforcement officers who affirm that they detect the odor of raw marijuana based on their training and experience may establish probable cause without providing further details on their qualifications to recognize this specific odor. View "Bunnell v. State" on Justia Law

The Supreme Court reversed in part the judgment of the trial court awarding Plaintiff $132,000 in damages in connection with her negligence complaint, holding that the trial court erred in failing to apply the eggshell-skull rule.Plaintiff sued Defendant for negligence, and the trial court granted a default judgment. Plaintiff requested over $600,000 in damages. The trial court ultimately awarded her $132,000 in damages, noting Plaintiff's failure to mitigate her damages and failure to show that the accident in this case caused all of her damages. The Supreme Court held that the trial court abused its discretion in calculating damages, holding (1) the trial court properly reduced its award due to Plaintiff's failure to mitigate her damages; (2) the trial court did not err in determining that Plaintiff failed to prove Defendant's negligence proximately caused all her damages; but (3) the trial court erred in failing to apply the eggshell-skull rule. The Supreme Court remanded the matter for the trial court to recalculate its award of damages. View "Renner v. Shepard-Bazant" on Justia Law

The Supreme Court affirmed the order of the trial court granting summary judgment to Defendant and dismissing Plaintiff's fraudulent concealment claim, holding that Plaintiff's claim was untimely.Plaintiff, having been misinformed of a medical diagnosis by her provider, brought this medical malpractice complaint seeking relief for her injuries on grounds of fraudulent concealment, despite expiration of the applicable limitation period. The trial court ruled for Defendant. On appeal, Plaintiff argued that Defendant's fraudulent concealment of her test results tolled the five-year limitation period. The Supreme Court affirmed, holding (1) fraudulent concealment may not extend the time in which to file a claim; and (2) even if the limitation period were subject to tolling, Defendant's constructive fraud precluded equitable relief. View "Blackford v. Welborn Clinic" on Justia Law

The Supreme Court remanded this property valuation matter for further proceedings, holding that the use of a now-defunct tax appeal form challenging assessments to certain homeowners' association lands for the years 2001, 2002 and 2003 was proper.Petitioners, homeowners' associations located in Marion County, filed petitions for correction of an error (Form 133) alleging that property tax assessments from the years 2001 through 2003 were illegal because certain common areas of the properties were so encumbered by restrictions that the land had no value. The Marion County Property Tax Assessment Board of Appeals denied the forms. The Tax Court affirmed in part and reversed in part, holding in part that the HOAs' claim was not proper for a Form 133. The Supreme Court reversed in part and summarily affirmed in part, holding that Form 133 was a proper avenue to challenge the application of a discount to common land within the HOAs' property. View "Muir Woods Section One Ass'n Inc. v. Marion County Assessor" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Appellant's petition for post-conviction relief raising challenges to the effectiveness or his trial and appellate counsel, holding that Appellant's claims failed, and he was not entitled to relief.Appellant was convicted of three counts of murder and three counts of criminal recklessness and was sentenced to death. Appellant later filed a petition for post-conviction relief, alleging several claims of ineffective assistance of trial counsel. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claims that his trial counsel were constitutionally ineffective at all phases of Appellant's trial; (2) appellate counsel were not ineffective for failing to raise fundamental-error challenges on direct appeal concerning certain instructions; and (3) Appellant was not entitled to relief on his freestanding challenges to the post-conviction court's rulings. View "Isom v. State" on Justia Law

The Supreme Court accepted a question certified by the United States Court of Appeals for the Seventh Circuit and answered that the Indiana Medical Malpractice Act applies when a plaintiff alleges that a qualified healthcare provider treated someone else negligently and that the negligent treatment injured the plaintiff.Plaintiff was the husband and father of two individuals killed in a car crash caused by Physician's patient. Plaintiff filed a civil action in federal court alleging that Physician's negligence in prescribing opiates to his patient caused the wrongful deaths of his wife and daughter. The state insurance commissioner, who administered the Patient's Compensation Fund, received permission to intervene. Plaintiff settled with Physician, who was dismissed. Plaintiff then sought excess damages from the Fund. The Fund responded that it had no liability because the underlying claim was not covered by the Act. The district court entered judgment for the Fund. On appeal, the Seventh Circuit certified to questions to the Supreme Court. The Supreme Court declined to answer question one and answered question two in the affirmative, holding that the Act applies where a plaintiff alleges that a qualified healthcare provider's negligent treatment of someone else caused the plaintiff to suffer an injury. View "Cutchin v. Beard" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Husband had breached a provision of the parties' settlement agreement entered into during their dissolution of marriage action, holding that the trial court did not abuse its discretion in finding that Husband had breached the warranty clause of the agreement.During dissolution proceedings, Wife and Husband signed a settlement agreement under which each party retained all stock accounts in their respective names and Husband received all jointly held stock accounts. The agreement contained a warranty stating that the parties would truly reveal to each other their assets and debts. Wife subsequently filed a motion for relief from judgment, alleging that the agreement should not be enforced due to the omission of a stock account from a balance sheet used in determining the division of assets. The trial court awarded Wife half of the value of the account, concluding that fraud, constructive fraud, mutual mistake, or misrepresentation had occurred. The Supreme Court affirmed, holding (1) Wife's evidence was inadmissible to avoid the agreement, and the trial court incorrectly determined that fraud, constructive fraud, mutual mistake, or misrepresentation had occurred; but (2) the trial court did not abuse its discretion in finding that Husband had breached the warranty clause of the agreement. View "Berg v. Berg" on Justia Law

The Supreme Court reversed the order of the trial court directing the State to produce a confidential informant (CI) for a face-to-face interview with Defendant's counsel, holding that because the trial court did not apply the established balancing test before ordering disclosure, remand was required.The CI in this case relayed the names of two men who broke into a woman's house and assaulted and robbed her and said that a third man, later identified as Defendant, had organized the crimes. Jones sought to interview the CI, and the trial court ordered the State to produce the CI for a face-to-face interview with Defendant's counsel. The State brought this interlocutory appeal. The Supreme Court reversed the trial court's order, holding (1) because a CI's physical appearance during a face-to-face interview reveals the informant's identity, any request for such a meeting triggers the informer's privilege; and (2) because the trial court did not engage in the necessary balancing inquiry to determine whether an exception to nondisclosure was warranted, remand was necessary. View "State v. Jones" on Justia Law