Justia Indiana Supreme Court Opinion Summaries

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The Supreme Court reversed the decision of the trial court awarding attorney's fees to Defendants in this dispute over the proposed construction of seven billboards, holding that the trial court's decision to award attorney's fees was an abuse of discretion.River Ridge Development Authority (RRDA) sued Defendants seeking a declaration that seven billboards that were set to be constructed near the planned entrance of RRDA's $25 million expansion to The River Ridge Commerce Center violated the Town of Utica's zoning ordinance. During the litigation, the relevant portion of the road along which the billboards were to be constructed was approved to become a scenic byway. Thereafter, RRDA voluntarily dismissed its complaint with prejudice. Defendants filed motions to recover attorney's fees, claiming that RRDA's behavior during litigation justified such an award. The trial court granted the motions in full. The Supreme Court reversed, holding (1) on the record, Defendants failed to show that any exception to the American Rule requiring each party to pay its own attorney's fees applied; and (2) therefore, the trial court abused its discretion in awarding attorney's fees. View "River Ridge Development Authority v. Outfront Media, LLC" on Justia Law

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The Supreme Court reversed the decision of the trial court denying Defendant's request to file a belated notice of appeal of his twelve-year sentence, holding that the general waiver of Defendant's "right to appeal" was insufficiently explicit to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence.Defendant pleaded guilty to Level 4 felony dealing in methamphetamine and was sentenced to the maximum term of twelve years incarceration. Defendant did not timely file a notice of appeal. Defendant later sought permission to file a belated notice of appeal, arguing that he was only recently made aware of his right to appeal his sentence. The trial court denied Defendant's request. The Supreme Court reversed, holding that the general waiver of Defendant's "right to appeal," particularly when contained in the same sentence as an unenforceable waiver of post-conviction relief, was insufficient to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence. View "Johnson v. State" on Justia Law

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The Supreme Court revised Defendant's sentence for three counts of level 3 felony rape but otherwise affirmed the court of appeals' decision affirming Defendant's convictions and sentence, holding that exceeding the sentence the prosecutor recommended in this case, absent more significant aggravating factors, was inappropriate.Defendant's convictions arose from his having sexual intercourse with K.S. when she was between twenty-one and twenty-three years old. At issue was whether K.S., who was moderately intellectually handicapped, could legally consent to sex with Defendant. After a mistrial, a second jury convicted Defendant of three counts of rape. The prosecutor recommended that the court impose the advisory sentence of nine years for each of the three counts. The trial court instead sentenced Defendant to enhanced consecutive sentences of twelve years on each count. The court of appeals affirmed. The Supreme Court reversed Defendant's sentence to twenty-seven years, holding that the longer imposed sentence was inappropriate under the circumstances of this case. View "Jackson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's guilty but mentally ill (GBMI) conviction to find him not guilty of reason of insanity (NGRI), holding that the State presented insufficient demeanor evidence with which to rebut the unanimous expert opinion and evidence of Payne's history of mental illness.In 2005, Defendant confessed to burning down two bridges and attempting to burn another. Defendant spent most of his life under psychiatric care for chronic paranoid schizophrenia and delusional disorder. The trial court found Defendant incompetent to stand trial until 2016. At his jury trial, Defendant asserted the insanity defense. Three mental health experts concluded that Defendant was unable to distinguish right from wrong. Nevertheless, the jury rejected the insanity defense and found Defendant GMBI on all counts. The court of appeals affirmed. The Supreme Court reversed the GBMI conviction to find Defendant NGRI, holding that the well-documented and consistent history of Defendant's mental illness, along with the unanimous expert opinion, leads to the conclusion that Defendant was insane when the crimes were committed. View "Payne v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the trial court's grant of summary judgment for Defendants, holding that the trial court erred by entering summary judgment for defendant health-insurance plans, which were governed by the Employee Retirement Income Security Act of 1974 (ERISA), based on ERISA preemption.Plaintiff, a health-care provider, contracted with two third-party networks. Defendants and its affiliated employee health-insurance plans contacted with both health networks. Seven patients received treatments from Plaintiff, and the patients were covered under Defendants' plans. Plaintiff sued Defendants, alleging that they failed to pay agreed reimbursement rates for covered services under their plans. The trial court granted summary judgment against Plaintiff, concluding that Plaintiff's claims were preempted under ERISA's conflict-preemption provision, 29 U.S.C. 1144(a). The Supreme Court vacated the judgment, holding that genuine issues of disputed fact existed concerning the central issue of whether the provider's claims were denied coverage under the plans or whether the provider's claims necessitated interpreting the plan documents. View "FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc." on Justia Law

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The Supreme Court found that Respondent, the Attorney General of Indiana, committed acts of misdemeanor battery, conduct that violated Indiana Professional Conduct Rules 8.4(b) and 8.4(d), and that Respondent should be suspended for thirty days with automatic reinstatement.The Indiana Supreme Court Disciplinary Commission filed a disciplinary complaint against Respondent alleging that his conduct at a local bar involving various forms of nonconsensual and inappropriate touching violated Indiana Professional Conduct Rules 8.4(b) and 8.4(d). A hearing officer found that Respondent violated the rules and recommended that Respondent be suspended for at least sixty days without automatic reinstatement. The Supreme Court concluded that Respondent violated Rules 8.4(b) and 8.4(d) and suspended Respondent from the practice of law for a period of thirty days. View "In the Matter of Curtis T. Hill, Jr." on Justia Law

Posted in: Legal Ethics
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The Supreme Court reversed the judgment of the juvenile court finding that R.L. was a child in need of services (CHINS), holding that the Department of Child Services (DCS) should have been barred from filing a successive CHINS action after the initial CHINS petition was dismissed with prejudice.In 2017, DCS filed a petition alleging that R.S. was a CHINS. The juvenile court determined R.L. was not a CHINS and dismissed the action with prejudice. In 2018, DCS filed a subsequent petition alleging R.L. was a CHINS. Mother moved to dismiss the petition on claim preclusion grounds. The juvenile court denied the motion and found R.L. was a CHINS. The Supreme Court reversed, holding that Mother's motion to dismiss should have been granted because, under the framework of Matter of Eq.W., 124 N.E.3d 1201 (Ind. 2019), the subsequent petition filed by DCS should have been barred by the doctrine of claim preclusion. View "R.L. v. Indiana Department of Child Services & Child Advocates, Inc." on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the decision of the court of appeals that a parent is not entitled to dismissal of a termination of parental rights petition due to the juvenile court's failure to complete a hearing within the statutorily required 180 days where the parent affirmatively waived that requirement, holding that relief is not available under these circumstances.The Indiana Department of Child Services filed petitions to terminate Mother's parental rights regarding her two children. The evidentiary hearing on the petitions was completed more than 180 days after the petitions were filed. Thereafter, the court terminated Mother's parental rights. The court of appeals affirmed. The Supreme Court affirmed, holding that because Mother affirmatively waived the 180-day requirement and invited the court to conduct the hearing without regard to it, Mother was precluded from later successfully invoking it as a basis for reversal. View "J.C. v. Indiana Department of Child Services" on Justia Law

Posted in: Family Law
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The Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment for Defendant and dismissing Plaintiff's wrongful termination claim, holding that the record did not support summary judgment in this case.Plaintiff, a former at-will employee working as a police officer, was allegedly terminated for stealing food from the cafeteria. In this action, Plaintiff alleged that the true reason for his termination was adverse testimony he gave in an unemployment compensation appeal hearing on behalf of a former coworker. In granting summary judgment for Defendant, the trial court concluded that because Plaintiff was not subpoenaed to testify, his testimony did not fall within the public policy exception to at-will employment, which would have barred his firing. The court of appeals affirmed. The Supreme Court reversed, holding (1) even though Plaintiff was not provided a paper subpoena before testifying, he was constructively compelled to testify once he was at the hearing; and (2) therefore, Plaintiff's testimony was protected under the public policy exception to at-will employment. View "Perkins v. Memorial Hospital of South Bend" on Justia Law

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In this dispute over the ownership of a criminal justice center the Supreme Court affirmed the judgment of the trial court ordering that the title of the center be given to Floyd County, holding that the turn-over provision in the lease between the County and the Building Authority was valid and enforceable.In 1991, the New Albany, Floyd County Indiana Building Authority issued bonds to finance a criminal justice center (the Center). Pursuant to an inter-local agreement, the Building Authority would own the Center, the County would lease it, and the City of New Albany would sublease space from the County. In 1992, the County and the Building Authority executed a lease with a fifteen-year term. The lease included a turn-over provision providing that if the County did not exercise its option to purchase the Center and to renew the lease then upon expiration of the lease the Center should become property of the County. After the lease expired the Building Authority declined to transfer title. The County filed suit seeking declaratory judgment and specific performance. The Supreme Court held that the turn-over provision in the lease was valid and required that title be given to the County. View "City of New Albany v. Board of Commissioners of County of Floyd" on Justia Law