Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant did not receive ineffective assistance of counsel at sentencing, holding that Defendant did not receive ineffective assistance of counsel.Defendant was convicted of murdering his brother when Defendant was seventeen years old. Defendant sought post-conviction relief alleging that he received ineffective assistance of counsel at sentencing. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that counsel's performance fell objectively below professional norms or that he was prejudiced by any of counsel's alleged errors. View "Conley v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this marital dissolution case, holding that a trial court need not follow a rigid, technical formula in dividing the marital estate so long as the court expressly considers all marital property and offers sufficient justification to rebut the presumptive equal division.In its final decree, the trial court granted Wife's request for spousal maintenance and awarded Wife fifty-five percent of the "net marital estate." On appeal, both Husband and Wife disputed the trial court's award of spousal maintenance and the distribution of the marital estate. The Supreme Court affirmed, holding (1) there was no error in the trial court's award of spousal maintenance; and (2) there was no error in the court's division of marital property. View "Roetter v. Roetter" on Justia Law

In this dispute arising from a supplier's sale of steel for a project to a fabricator who did not perform any work on the project site, the Supreme Court reversed the order of the trial court granting summary judgment for the site's owner, holding that the trial court did not err.The supplier in this case sued to foreclose on its mechanic's lien against the project site. In granting summary judgment for the site's owner, the trial court concluded that the fabricator's lack of on-site work meant that it was also a supplier, and case law barred supplier-to-supplier liens. The Supreme Court reversed, holding (1) under Indiana's mechanic's lien statute a supplier that furnished materials for the erection of a building, regardless of the recipient, can have a lien on that building and the accompanying land; and (2) because the supplier furnished steel for the project, the supplier could have a lien on the project site. View "Service Steel Warehouse Co., L.P. v. United States Steel Corp." on Justia Law

The Supreme Court reversed a portion of the utility regulatory commission's order that approved in part Duke Energy's request to increase its rates for retail consumers, holding that, absent specific statutory authorization, a utility cannot recoup its past costs adjudicated under a prior rate case by treating the costs as a capitalized asset.In 2020, the commission granted Duke's petition for a rate increase in part permitting Duke to recover about $212 million for coal-ash site closures, remediation, and financing costs, with the bulk of the costs having been incurred from 2015 to 2018. At issue was whether the commission could approve reimbursement for a deferred asset without violating the statutory bar against retroactive ratemaking. The Supreme Court answered in the negative, holding that the commission acted without statutory authority in re-adjudicating expenses already governed by a prior rate order. View "Indiana Office of Utility Consumer Counselor v. Duke Energy Indiana, LLC" on Justia Law

The Supreme Court held that a breach of contract claim for failure to indemnify need not follow the procedures contained in the Medical Malpractice Act (MMA).While Joseph Shaughnessy was a patient at Franciscan Alliance, Inc., Lake Imaging LLC interpreted two CT scans performed on Joseph. Joseph subsequently died. Joseph's sons filed with the Department of Insurance (DOI) a proposed medical-malpractice complaint against Franciscan without naming Lake Imaging. The DOI served the proposed complaint on Franciscan, which settled with the Shaughnessys. Franciscan then filed suit against Lake Imaging, alleging breach of contract. The trial court dismissed the claim. The court of appeals affirmed, concluding that because Franciscan's claim rested on Lake Imaging's alleged medical negligence, the MMA's two-year statute of limitations applied, and thus the complaint was untimely filed. See Ind. Code § 34-18- 7-1(b). The Supreme Court reversed, holding that the MMA did not apply in this case, and therefore, the trial court had subject matter jurisdiction and the MMA's statute of limitations did not apply. View "Lake Imaging LLC v. Franciscan Alliance, Inc." on Justia Law

The Supreme Court dismissed this appeal brought by Solarize Indiana, Inc. seeking judicial review of the administration decision of the Indiana Utility Regulatory Commission (IURC) approving two filings submitted by Vectren Energy Delivery of Indiana, Inc. under an expedited process known as the "Thirty-Day Rule," holding that Solarize lacked standing to bring this appeal.In objecting to Vectren's filings, Solarize, an organization that promotes the use of solar power in Indiana, asserted that the filings were not compliant with federal law. The IURC approved the filings, after which Solarize requested judicial review. The Supreme Court dismissed the appeal, holding that Solarize lacked standing because it failed to show that it was "adversely affected" by the IURC's order. View "Solarize Indiana, Inc. v. Southern Indiana Gas & Electric Co." on Justia Law

In this insurance dispute, the Supreme Court held that the MCS-90 endorsement, which provides that if a motor vehicle is involved in an accident the insurer may be required to pay any final judgment against the insured arising out of the accident, does not apply to an accident that occurred during an intrastate trip transporting non-hazardous property.One way motor carries can comply with the financial requirements of the federal Motor Carrier Act of 1980 is by adding an MCS-90 endorsement to their insurance policy. The insurer in this case brought an action seeking a declaration that the MCS-90 endorsement creating a suretyship whereby the insurer agreed to pay a final judgment against the insured in certain negligence cases did not apply. The trial court found that the MCS-90 endorsement applied, and the court of appeals affirmed. The Supreme Court reversed, holding (1) because the insured driver was neither engaged in interests commerce at the time of the action nor transporting hazardous property, the MCS-90 endorsement did not apply; and (2) the insurer had no duty to defend or indemnify the driver. View "Progressive Southeastern Insurance Co. v. Brown" on Justia Law

The Supreme Court held that probation officers are state employees for purposes of Ind. Code 4-6-2-1.5, which requires the Attorney General to defend state employees, and that the statute applies to probation officers.This dispute arose from the facts that the General Assembly has granted the judiciary primary authority over probation officers' employment, that precedent has recognized that probation officers are court employees, but that counties are responsible for paying probation officers' salaries and certain expenses. At issue before the Supreme Court was how to determine which entity was responsible for defending and indemnifying probation officers in a lawsuit. The trial court ultimately concluded that the county was responsible for both the officers' representation and payment of any judgment against them. The Supreme Court reversed, holding (1) probation officers are state employees for purposes of the general statute requiring the Attorney General to defend state employees; and (2) that statute applies to probation officers. View "Lake County Board of Commissioners v. State" on Justia Law

The Supreme Court affirmed the trial court's order denying Petitioner's motion for bond reduction or conditional pretrial release, holding that the General Assembly's recent codification of Criminal Rule 26 and the adoption of evidence-based practices in the administration of bail enhances, rather than restricts, the discretion entrusted to trial courts when executing bail.Petitioner was charged with the level-two felony offense of aiding, inducing, or causing burglary with a deadly weapon. The trial court set Petitioner's bond at $50,000 cash-only. After she was found eligible for home detention, Petitioner filed a motion for a bond reduction or conditional pretrial release. The court of appeals denied the motion. The Supreme Court affirmed, holding (1) trial courts should consider any factor relevant to the detainee's risk of nonappearance and potential danger to the community, and Indiana's recent bail reforms enhance the courts' discretion; and (2) clear and convincing evidence supported the trial court's bail determination. View "Dewees v. State" on Justia Law

The Supreme Court summarily affirmed the opinion of the court of appeals dismissing in part, affirming in part, and reversing in part the judgment of the trial court in this criminal case but reversed the court of appeals' conclusion that remand for a new sentencing was unnecessary, holding that remand was necessary.Defendant was convicted of several offenses for driving his vehicle while intoxicated with his three young grandchildren in the vehicle. On appeal, Defendant argued that his multiple convictions constituted double jeopardy and that the trial court erred in sentencing. The court of appeals remanded the case in part with instructions. The Supreme Court summarily affirmed with one exception, holding that, given the multiple irregularities in Defendant's sentence, remand for resentencing was appropriate. View "McDonald v. State" on Justia Law