Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murdering twenty-three-month-old P.H. and neglecting three-year-old R.H., resulting in serious bodily injury, holding that none of the alleged errors on appeal warranted reversal.The jury in this case found two statutory aggravators beyond a reasonable doubt and recommended life imprisonment without the possibility of parole for Defendant's murder conviction. The trial court adopted the jury's recommendation. The Supreme Court affirmed Defendant's convictions and sentences, holding that the trial court (1) did not err in its evidentiary rulings; (2) did not err in giving a supplemental jury instruction; and (3) did not err in sentencing Defendant to life without parole. View "Ramirez v. State" on Justia Law

The Supreme Court held that when a property's assessment increases by more than five percent over the previous year and the Indiana Board of Tax Review finds incorrect both parties' assessment, a statutory clause requires that the assessment reverts to the assessment for the prior tax year.In 2014, the Ross Township assessor in Lake County increased the tax assessment for Southlake Mall, Owned by Southlake Indiana, LLC. The new assessed values were more than double the assessments for the three prior tax years. The tax court affirmed in all respects except for a pair of reimbursements not at issue on appeal. Southlake appealed, arguing that the tax court erred by not applying the reversionary clause in Ind. Code 6-1.1-15-17.2(b). The Supreme Court reversed, holding that because neither party met its burden of proof, section 17.2's reversionary clause controlled, requiring that the assessments revert to the assessment for each prior tax year. View "Southlake Indiana LLC v. Lake County Assessor" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting summary judgment on Plaintiff's negligence claim based on a determination that no duty was owed in this case, holding that there was no error.Plaintiff's husband suffered catastrophic injuries when the motorcycle he was operating was hit by a car in an intersection. Plaintiff brought this action against Defendant, alleging negligence for allowing the property it owed to grow grass so high that it blocked the view of the roadway. The trial court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Defendant did not owe a duty to nearby motorists. View "Reece v. Tyson Fresh Meats, Inc." on Justia Law

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