Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of molesting and murdering an eighteen-month-old boy, holding that the trial court did not commit fundamental error by admitting improper character evidence and medical-personnel testimony and that Defendant was not entitled to relief based on his challenged aggravators.During sentencing, the jury found three statutory aggravators beyond a reasonable doubt and recommended life imprisonment without parole. The trial court adopted the recommendation. The Supreme Court affirmed, holding (1) Defendant failed to show that the trial court committed fundamental error by admitting certain testimony; and (2) the State introduced sufficient evidence during sentencing to support the torture and child-molest aggravators. View "Tate v. State" on Justia Law

In this challenge to an appraiser's valuation of corporate shares, the Supreme Court held that the shareholder agreement's valuation term clearly contemplated a fair market valuation of the selling shareholder's shares.Plaintiff, who held a minority portion of the shares of BigInch Fabricators & Construction Holding Company, Inc., a closely held corporation, was terminated without cause. Applying a fair market value standard, an appraiser hired by BigInch discounted Plaintiff's shares for their lack of marketability and Plaintiff's lack of control. Plaintiff brought this action seeking a declaratory judgment that the discounts were inapplicable because the shareholder agreement did not contemplate a fair market value standard. The trial court granted summary judgment for BigInch. The Supreme Court affirmed, holding that the plain language of the shareholder agreement called for BigInch to pay Plaintiff the fair market value of his shares, and so a third-party appraiser could apply minority and marketability discounts. View "Hartman v. BigInch Fabricators & Construction Holding Co." on Justia Law

The Supreme Court reversed the determination of the trial court that Jane Doe could compel her legal guardian (Guardian) to arbitrate her claims against it and affirmed the trial court's order compelling Guardian to arbitrate as to the remaining defendants, holding that this Court declines to adopt any alternative theories to the doctrine of equitable estoppel.After Jane had been living at Carmel Senior Living (CSL) for a few months, Guardian filed a complaint against CSL, CSL's management company and one of its employees, and Certiphi Screening, the company CSL had hired to run background checks on new employees, alleging that Jane had been sexually abused. The trial court granted CSL's and Certiphi's motions to compel arbitration under the arbitration agreement in the residency contract, determining that the agreement covered CSL under and agency theory and that equitable estoppel mandated arbitration of Guardian's claims against Certiphi. The Supreme Court reversed in part, holding (1) Certiphi was not one of the third-party beneficiaries provided for in the arbitration agreement and could not meet the requirements of equitable estoppel; and (2) this Court declines to endorse any alternative equitable estoppel theories. View "Doe v. Carmel Operator, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Appellant's petition for expungement, holding that because the trial court may have denied the petition on the erroneous belief that Ind. Code 35-38-9-4(b)(3) rendered Defendant ineligible for expungement, remand was required.Appellant pled guilty to Class B felony conspiracy to commit burglary. After completing the terms of his probation without any violations and waiting the required three years, Appellant petitioned for expungement under section 35-38-9-4. The trial court denied the petition for expungement without explaining its reasoning. The Supreme Court reversed, holding (1) a trial court may consider facts incident to the conviction when evaluating an expungement petition; and (2) because the trial court did not articulate why it denied Appellant's petition, the case must be remanded with instructions for the court to reconsider its decision consistent with this opinion. View "Allen v. State" on Justia Law

The Supreme Court remanded this custody matter for further proceedings, holding that the trial court abused its discretion by conflating Mother's contempt of court with the best interest of the child.Father filed a petition to request DNA testing, establish paternity, physical custody, parenting time and child support. Later, the trial court found Mother in contempt for relocating the child out of Indiana and for denying Father parenting time. The court then ordered that Father should have sole legal and physical custody of the child. The Supreme Court reversed and remanded the matter for additional proceedings, holding that Mother's alleged contempt was not so severe as to remove the child from her care. View "Yanes-Mirabal v. Badasay" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this declaratory judgment action against Governor Holcomb, holding that the statute passed by the legislature in 2017 stopping the City of Bloomington's proposed annexation of several areas of land and prohibiting the City from trying to annex the areas for five years is unconstitutional special legislation in violation of Ind. Const. art. IV, 23.In 2017, the Bloomington mayor announced plans for a proposed annexation of several areas of land. After the City Council adopted the initiating resolutions and Bloomington took its initial steps toward annexation, the General Assembly passed legislation codified at Ind. Code 36-4-3-11.8 cutting off Bloomington's proposed annexation and prohibiting the City from trying to annex the same areas for the next five years. The City brought this suit seeking declarations that section 11.8 constitutes unconstitutional special legislation and violates article 4, section 19's single-subject rule. The trial court declared section 11.8 unconstitutional under article 4, sections 19 and 23 of the Indiana Constitution. The Supreme Court affirmed, holding that section 11.8 constitutes impermissible special legislation. View "Holcomb v. City of Bloomington" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct but that it was not likely that Defendant was harmed by the misconduct.The juror at issue wrote "N/A," meaning not applicable, in response to jury questions on her jury questionnaire regarding her past criminal history and whether she had herself been a victim of a crime. The juror, however, had in fact been charged with a crime and had been the victim of domestic abuse. The court of appeals reversed the convictions, finding that the trial court erred in not finding that the juror's false answers amounted to gross misconduct that probably harmed Defendant. The Supreme Court reversed, holding that, despite the jurors gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of "dealing in a look-a-like substance," a level five felony under Ind. Code 35-48-4-4.6, holding that trial court did not err in denying Defendant's motion to suppress.At a casino, Defendant offered to sell a substance to a stranger, who reported the incident. Thereafter, a Gaming Enforcement Agent led Defendant to an interview room and proceeded to pat him down. The trial court admitted the evidence discovered as a result of the pat down. The Supreme Court affirmed, holding (1) the search and seizure proceeded within the bounds of the Fourth Amendment; and (2) therefore, the trial court did not abuse its discretion in admitting evidence obtained as a result. View "Johnson v. State" on Justia Law

The Supreme Court reduced Defendant's aggregate sentence to 100 years, holding that Defendant's appellate counsel was ineffective on appeal by failing to bring an Appellate Rule 7(B) challenge to the appropriateness of Defendant's sentence.Defendant was convicted of two counts of murder, felony armed robbery, and felony conspiracy to commit criminal gang activity. The trial court sentenced Defendant to an aggregate sentence of 181 years. Defendant later sought post-conviction relief, arguing that, because he was a juvenile when he committed the crimes at issue, the criminal gang enhancement was unconstitutional as applied and that both his trial counsel and appellate counsel were ineffective. The post-conviction court denied Defendant's petition for relief. The Supreme Court revised Defendant's sentence downward to an aggregate 100 years, holding (1) Defendant's original sentence was not unconstitutional under the Eighth Amendment because the sentence was not subject to the requirements of Miller v. Alabama, 567 U.S. 460 (2012); but (2) Defendant's appellate counsel performed inadequately by failing to request appellate review of the sentence's appropriateness under Appellate Rule 7(B). View "Wilson v. State" on Justia Law

The Supreme Court reversed Defendant's maximum 138-year sentence imposed for crimes Defendant committed as a juvenile and revised the sentence to a total sentence of eighty-eight years, holding that the 138-year sentence was inappropriate.Defendant was seventeen years old when he and two others committed murder in 1991. Defendant received an aggregate sentence of 138 years, which was the maximum possible term-of-years sentence. In 2016, Defendant filed a verified petition for post-conviction relief challenging the propriety of his sentence in light of the fact that he was a juvenile when he committed the crimes. The post-conviction court granted the petition and imposed an aggregate sixty-eight-year sentence. The Supreme Court affirmed the order granting relief and revisited its prior decision regarding the appropriateness of his sentence but revised the sentence to an aggregate term of eighty-eight years, holding (1) the doctrine of res judicata does not bar consideration of Defendant's appropriateness argument due to two major shifts in the law; and (2) Defendant's maximum term-of-years sentence imposed for crimes he committed as a juvenile was inappropriate. View "State v. Stidham" on Justia Law