Justia Indiana Supreme Court Opinion Summaries

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

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