Justia Indiana Supreme Court Opinion Summaries

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

The Supreme Court reversed in part and affirmed in part the order of the trial court finding that HEA-1123 is constitutional, holding that Governor Eric J. Holcomb was not procedurally barred from seeking declaratory relief on the constitutionality of House Enrolled Act 1123 (HEA-1123) and that the law is unconstitutional.HEA-1123, which was passed during the COVID-19 pandemic, authorizes the General Assembly to commence an "emergency session" under certain conditions through a simple resolution. The Governor vetoed the bill, finding it unconstitutional. The General Assembly overrode the Governor's veto, and the law went into effect. The Governor filed suit. The trial court found the HEA-1123 was constitutional. The Supreme Court reversed, holding (1) HEA-1123 violates Ind. Const. art. III, 1; and (2) by authorizing the Legislative Council to set an emergency session at a time when the General Assembly was not in session, HEA-1123 infringed on constitutional authority vested only in the Governor. View "Holcomb v. Bray" on Justia Law

The Supreme Court affirmed Defendant's conviction for level-2 felony burglary while armed with a deadly weapon but reversed his sentence, holding that the length of Defendant's aggregate sentence exceeded the consecutive sentencing cap imposed by Ind. Code 35-50-1-2.A jury found Defendant guilty as charged and sentenced him to consecutive sentences cultivating in an aggregate term of thirty-eight and one-half years. The Supreme Court reversed in part, holding (1) burglary is an ongoing crime that encompasses a defendant's conduct inside the premises, terminating only when the unlawful invasion ends; and (2) the length of Defendant's aggregate sentence exceeded the maximum aggregate sentence permitted by the Sentencing Cap Statute. View "Fix v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to four charges, including operating a vehicle while intoxicated and possession of marijuana, holding that any error was harmless.The trial court sentenced Defendant to a total of six years, with two suspended to probation. On appeal, Defendant argued that the trial court committed fundamental error by incorrectly advising him of his right to allocution. The Supreme Court affirmed, holding that Defendant failed to prove that his sentence would have been different had he not testified and been subject to cross-examination. View "Strack v. State" on Justia Law

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