Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court denying Defendant's motion arguing that he should receive credit time from the date of his erroneous release through his readmission to the Department of Corrections (DOC), holding that Defendant was entitled to credit time as if he were still incarcerated during the period erroneously spent at liberty.Upon intake to the DOC, Defendant was erroneously awarded 450 days of jail credit. Consequently, Defendant was released from custody with 450 days left on his sentence. The State subsequently requested that Defendant be readmitted to the DOC to serve the time owed on his felony sentence. The trial court ordered that Defendant be returned to the DOC to finish serving his sentence. The Supreme Court reversed and remanded the case, holding that, as long as the defendant bears no active responsibility in his early release, he is entitled to credit while erroneously at liberty as if still incarcerated. View "Temme v. State" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of an appellate panel finding that the City of Marion's claims alleging corruption in the old City administration were time barred, holding that, under the adverse domination adopted today, summary judgment was inappropriate for all the City's claims.The City sued London Witte Group, LLC, an advisor to the City's former mayor, Wayne Seybold, alleging that the former administration was corrupt, a corruption that was aided and abetted by London Witte. After London Witte moved for summary judgment based on the statute of limitations the City responded that the doctrine of adverse domination tolled the statute of limitations until Mayor Seybold left office. The trial court granted partial summary judgment for London Witte. The court of appeals affirmed summary judgment on the first two counts and reversed the denial of summary judgment for the third count, concluding that the third count was time barred. The Supreme Court reversed, holding (1) this Court adopts the equitable tolling doctrine of adverse domination as a logical corollary of Indiana's discovery rule; and (2) summary judgment was inappropriate because there were genuine issues of material fact as to whether Mayor Seybold adversely dominated the City and whether London Witte contributed to it. View "City of Marion v. London Witte Group, LLC" on Justia Law

The Supreme Court ruled that the forfeiture of Tyson Timbs's his white Land Rover was unconstitutional, holding that Timbs met his high burden to show that the harshness of his Land Rover's forfeiture was grossly disproportionate to the gravity of the underlying offense and his culpability for the vehicle's misuse.The State filed a civil forfeiture complaint alleging that Timbs had used his Land Rover to illegally purchase, possess, and deal narcotics. The trial court entered judgment for Timbs. The case made its way up to the Supreme Court of the United States. On remand, the Supreme Court held that the Excessive Fines Clause of the Eighth Amendment includes both instrumentality and proportionality limitations for use-based in rem fines like the forfeiture of Timbs's vehicle and that such fines are constitutional if two requirements are met. The Supreme Court held that the forfeiture fell within the Excessive Fines Clauses's instrumentality limit but remanded for the trial court to determine whether the harshness of the forfeiture penalty was grossly disproportional to the gravity of the offense. The trial court determined that Timbs had shown gross disproportionality. The Supreme Court affirmed, holding that Timbs met his burden to show gross disproportionality and that the Land Rover's forfeiture was unconstitutional. View "State v. Timbs" on Justia Law

The Supreme Court reversed the order of the trial court suppressing statements made by Defendant during a police interview, holding that the circumstances did not amount to a custodial interrogation.At issue was whether Defendant's freedom of movement was curtailed to a level associated with formal arrest when he had a free-flowing exchange in a detective's personal office. In granting Defendant's motion to suppress the trial court concluded that the circumstances were akin to a custodial interrogation and that the statements were obtained in violation of the Fifth Amendment. The Supreme Court disagreed and reversed the suppression order, holding that the limited curtailment of Defendant's freedom of movement did not amount to a formal arrest. View "State v. Diego" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress the fruits of an inventory search of the company van he was driving, holding that the van's seizure and search were lawful.Defendant was driving his company van when we served off the road, demolished a utility box, then drove to his nearby home. The responding officer found Defendant as he was parking in his front driveway and took him to the hospital for a blood test. Later, other officers conducted an inventory search of the van, which revealed pills in a bag under the driver's seat, and then towed the van as evidence of leaving the scene of an accident. Defendant was charged with several offenses and moved to suppress the pills. The trial court denied the motion to suppress, and a jury convicted Defendant of most of the charges. The Supreme Court affirmed, holding that the search and seizure of Defendant's van fell under recognized exceptions to the warrant requirement of the Fourth Amendment, and therefore, the police officers lawfully discovered the pills. View "Combs v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's request to represent himself during trial, holding that the trial court did not err in denying Defendant's request to self-represent.Defendant was charged with, among other things, murder and felony burglary. Defendant petitioned the trial court to represent himself, but the trial court denied the petition, concluding that Defendant equivocated in his desire to self-represent and that the request was based upon a misapprehended understanding of the law. The Supreme Court affirmed, holding (1) while Defendant's waiver of the right to counsel was knowing and voluntary, his waiver was neither unequivocal nor intelligent; and (2) therefore, the trial court properly denied Defendant's request to represent himself. View "Wright v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant's motion to suppress evidence seized during the search of his home, holding that a waiver of the "right against search and seizure" clearly informs the defendant that a search may be conducted without reasonable suspicion.When a defendant is processed for home detention, he normally signs an agreement in which he forgoes many of his rights. The agreement typically includes consent to allow community corrections to search the defendant's person or home to ensure compliance with the rules. Defendant in this case argued that the search of his home violated his Fourth Amendment rights because the contract he signed when he was placed on home detention didn't include a waiver of searches without reasonable suspicion. The trial court granted the motion to suppress. The Supreme Court reversed, holding that the contract unambiguously informed Defendant that he waived his right against search and seizure absent reasonable suspicion. View "State v. Ellis" on Justia Law

The Supreme Court reversed the judgment of the trial court for CompressAir and thus rejected CompressAir's claim that a certain transfer was fraudulent and remanded with instructions to enter judgment for New Nello Operating Company, holding that continuity of ownership between two companies is necessary for an exception to the general rule that, in a typical asset purchase, the buyer acquires the seller's assets but not its liabilities.This case turned on two exceptions to the rule that with an asset purchase the buyer typically does not take on the seller's liabilities - the first of which arises when the acquisition of assets amounts to a de facto merger and the second of which arises when the buyer is a mere continuation for all of the seller's liabilities. At issue was whether New Nello Operating Company was liable for Nello Corporation's debt to CompressAir. The trial court concluded that the strict foreclosure between Old Nello and New Nello was fraudulent, amounted to a de facto merger, and that New Nello was a mere continuation of Old Nello. The court then entered judgment against New Nello. The Supreme Court reversed, holding that continuity of ownership is necessary for the de-facto-merger and mere-continuation exceptions to apply. View "New Nello Operating Co., Inc. v. CompressAir" on Justia Law

The Supreme Court answered in the negative a certified question as to whether a store manager can be held liable for negligence when he is not directly involved in the accident at issue.In the underlying personal injury case Plaintiff sued Wal-Mart and Wal-Mart's store manager, Jim Clark, seeking damages. Plaintiff sued in state court, but Defendants sought to remove the case to federal court and the grounds that Clark, an Indiana citizen, was added solely to defeat federal diversity jurisdiction. Plaintiffs sought to remand the matter back to state court, alleging that there were issues of fact precluding a conclusion that Clark, who played on personal or direct role in the alleged injury, was fraudulently joined. The United States District Court sua sponte entered an order seeking guidance in resolving the issue of whether Clark could be liable as a defendant. The Supreme Court answered by holding that when there are no allegations that a store manager controlled the premises where the harm occurred, he cannot be held liable under Indiana law. View "Branscomb v. Wal-Mart Stores East, L.P." on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of attempted murder, holding that the trial court did not err in not allowing Defendant's mother as a witness to stay in the courtroom during Defendant's trial.Defendant was fifteen years old when he was waived into adult criminal court and convicted. Before trial, the State listed Defendant's mother as a potential witness, and at trial, the State requested a separation of witnesses order. The court ordered Defendant's mother to leave the courtroom, and the State never called her to testify. The Supreme Court affirmed, holding (1) a child in adult criminal court may use Ind. R. Evid. 615(c) to establish that a parent is "essential" to the presentation of the defense and is thus excluded from a witness separation order; (2) Defendant did not make the requisite showing under the rule; (3) Defendant waived his argument that a juvenile defendant has a due process right to have a parent present for criminal proceedings; and (4) Defendant's challenges to his sentence were unavailing. View "Harris v. State" on Justia Law