Justia Indiana Supreme Court Opinion Summaries

In this insurance dispute stemming from a fatal car collision, the Supreme Court vacated the judgment of the trial court granting summary judgment in favor of Insurer, holding that the decedent's estate was entitled to summary judgment on the issues of whether the decedent was an "insured person" and the availability of $25,000 in further UIM coverage under the decedent's parents' Allstate policy.Shelina Glover died in a car accident. The insurers of the two responsible drivers paid policy limits, and Glover's estate received separate settlements for underinsured-motorist (UIM) coverage from Glover's own carrier and from that of Glover's husband, who was driving the vehicle on the day of the accident. The Estate requested further UIM coverage under Glover's parents' Allstate policy. The trial court granted summary judgment for Allstate, concluding that the policy's offset and anti-stacking provisions barred the Estate from recovery because the amount the Estate received from other insurers exceeded the limits under the policy. The Supreme Court vacated the judgment, holding (1) Glover was an "insured person" under the policy; and (2) the Estate's UIM settlements were not offset against the policy's UMI limit, and therefore, the Estate had an additional $25,000 UIM coverage available to it under the Allstate policy. View "Glover v. Allstate Property & Casualty Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendants relief from a default judgment, holding that the trial court's assessments of the parties' credibility and demeanor were sufficient to establish at least "slight evidence" of excusable neglect.Plaintiff sued Defendants alleging that certain statements Defendants made constituted defamation and false reporting. Because Defendants did not enter appearances or respond to the complaint the trial court granted default judgment to Plaintiffs. The trial court granted Defendants' motion for relief from the default judgment, concluding that Defendants were sincerely confused about their obligation to respond. The Supreme Court affirmed and remanded the matter to the trial court for further proceedings, holding that the trial court's fact-sensitive judgments showed that Defendants were entitled to relief. View "Riddle v. Cress" on Justia Law

In these consolidated appeals, the Supreme Court held that under the clear and unambiguous language of several relevant statutes, a juvenile court did not have subject matter jurisdiction to waive two individuals into adult criminal court because neither fit the definition of a "child" at the time their respective delinquency petitions were filed.The State filed juvenile delinquency petitions against D.P. and N.B. for committing, when they were under the age of eighteen, what would be felony child molesting if committed by an adult. Both individuals were twenty-one or older at the time the delinquency petitions were filed. The State requested that D.P. and N.B. be waived into adult criminal court, and D.P. and N.B. moved to dismiss their respective cases for lack of subject matter jurisdiction. The motion to dismiss was denied in D.P.'s case and was granted in N.B.'s case. The Supreme Court affirmed the juvenile court's dismissal in N.B. and reversed in D.P. and remanded with instructions to grant the motion to dismiss, holding that a juvenile court does not have subject matter jurisdiction to waive an alleged delinquent offender into adult criminal court if the individual is no longer a "child." View "D.P. v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court awarding Plaintiff $40,000 in this personal injury action, holding that the trial court did not abuse its discretion in giving a failure to mitigate instruction.Plaintiff brought this action alleging negligence and respondeat superior against Defendants claiming that a vehicle accident caused a preexisting tumor in his eye to swell in size. At the conclusion of the evidence, Defendants asked for a jury instruction on failure to mitigate damages. The trial court gave the requested instruction. The trial court awarded Plaintiff $40,000. On appeal, Plaintiff argued that the mitigation instruction was unsupported by the evidence. The Supreme Court disagreed, holding that the trial court did not abuse its discretion in giving a failure to mitigate instruction. View "Humphrey v. Tuck" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's motion requesting reinstatement of his lawsuit against Franklin Township Community School Corporation, holding that the court did not abuse its discretion when it denied Appellant's motion for reinstatement.Nine days before the applicable statute of limitations expired, Appellant filed a negligence lawsuit against the School. The court dismissed the complaint after Appellant failed to respond to the School's motion to dismiss. Months later, Appellant filed three documents requesting reinstatement of his case. The trial court summarily denied the motion. The Supreme Court affirmed, holding that Appellant's request was in actuality an impermissible collateral attack on the trial court's dismissal order, and therefore, the court did not abuse its discretion in denying Appellant's motion. View "Smith v. Franklin Township Community School Corp." on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of attempted murder, holding that Defendant's actions, despite their proximity in space and time, amounted to two distinct, chargeable offenses.Defendant fired five to six shots in rapid succession at two victims sitting in an adjacent vehicle. Defendant seriously injured one of the victims. At issue was whether Defendant was guilty of one count of attempted murder for the single act of shooting or two counts of attempted murder, one count for each victim. The jury found Defendant guilty of two counts of attempted murder. On appeal, Defendant argued that his two convictions violated the state constitutional protection against double jeopardy. The Supreme Court affirmed, holding that because the evidence was sufficient to prove that Defendant fired his weapon multiple times with the dual purpose of intentionally killing both victims the multiple shots Defendant fired amounted to two chargeable offenses. View "Powell v. State" on Justia Law

The Supreme Court expressly overruled the constitutional tests set forth in Richardson v. State, 717 N.E.2d 32 (Ind. 1999), in resolving claims of substantive double jeopardy and adopted an analytical framework that applies the statutory rules of double jeopardy.The Richardson court adopted a comprehensive analytical framework constituting of a statutory elements test and an actual evidence test for deciding all substantive double jeopardy claims under Ind. Const. art. I, 14. Application of the tests, however, proved largely untenable, resulting in a patchwork of conflicting precedent and inconsistent standards. Defendant in this case was convicted of several offenses for leaving the scene of an accident after striking and injuring the victim while driving drunk. The Supreme Court overruled Richardson and adopted a framework that applies when a defendant's single act or transaction implicates multiple criminal statutes. The Court then held that Defendant's multiple convictions violated the statutory rules of substantive double jeopardy. View "Wadle v. State" on Justia Law

The Supreme Court reversed the decision of the trial court denying Defendant's motion for discharge under Indiana Criminal Rule 4(C), holding that, under the circumstances of this case, Defendant was entitled to discharge.After Defendant successfully suppressed certain evidence the State filed an interlocutory appeal. Rather than request a stay of the proceedings the State asked for a continuance during the pendency of its appeal. Only after Defendant moved for a discharge did the State belatedly asked for a stay of the proceedings. The trial court granted the request and denied Defendant's renewed motion for discharge. The Supreme Court reversed, holding (1) Rule 4(C)'s clock continued to tick until the State formally moved for a stay of the proceedings, and this time continued to count against Rule 4's one-year limitation in prosecuting the charged crimes; and (2) the State exceeded the one-year limitation. View "Battering v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of four felony counts and dismissing a firearm enhancement sua sponte, holding that the State failed to meet its burden to show that the trial court's implied finding of waiver and subsequent sua sponte dismissal of the firearm enhancement were contrary to law.After a trial, the jury found Defendant guilty of four felony counts, including aggravated battery as a Level 3 felony. After the trial court accepted the verdicts and excused the jury the State raised a firearm enhancement. The trial court responded that the enhancement was dismissed as a matter of course. After Defendant was sentenced the State appealed, arguing that the trial court abused its discretion by dismissing the firearm enhancement. The Supreme Court affirmed, holding that the State waived the enhancement and that the trial court's sua sponte dismissal of the firearm enhancement was not contrary to law. View "State v. Brake" on Justia Law

In this negligence action, the Supreme Court reversed the judgment of the trial court in favor of Defendant, holding that a juror should have been struck for cause based on bias and that there was prejudice because Plaintiff, the party objecting to the juror, was forced to exhaust her last peremptory challenge and accept and objectionable juror.The estate of Kandace Pyles brought a negligence claim against various medical providers, including Defendant. The juror in this case stated that he did not want to serve as a juror, that he had a favorable impression of doctors, and that he would not be able to assess noneconomic damages. Plaintiff moved to strike the juror for cause, and the trial court denied the motion. Plaintiff used her final peremptory challenge on the juror. After a trial, the jury found that Defendant was not negligent. The Supreme Court reversed and remanded the case for a new trial, holding that the trial court's decision to deny Plaintiff's for-cause challenge was illogical and that a new trial was appropriate. View "Clark v. Mattar" on Justia Law