Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court foreclosing a mortgage but finding that Lender was entitled to recover only payments and interest that accrued after a certain date due to Indiana's six-year statute of limitations to bring an action on the note underlying a mortgage, holding that there is no need to judicially create additional time constraints on a lender's ability to bring an action upon a closed installment contract.Lawsuits to enforce obligations under closed installment contracts are subject to multiple statutes of limitations. Borrowers in this case asked the Supreme Court to impose an additional rule of reasonableness. The trial court granted partial relief. The Supreme Court affirmed, holding (1) imposing additional, judicially-created time constraints upon a lender's ability to bring a claim on a closed installment contract is not necessary; (2) two statutes of limitations apply to a cause of action upon a promissory note; and (3) Lender sued within the applicable statutes of limitations. View "Blair v. EMC Mortgage, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court entering a second two-year protective order against Respondent, holding that there was insufficient evidence showing that Respondent presented a present, credible threat to Petitioner's safety in order to support the protective order.In 2016, Petitioner filed a petition seeking a protective order against Respondent. The trial court entered a two-year protective order against Respondent. In 2018, just days before the 2016 protective order was set to expire, Petitioner petitioned for another protective order against Respondent. After a hearing, the trial court issued another two-year protective order. The Supreme Court reversed, holding that there was insufficient evidence that Respondent posed a present, credible threat to Petitioner to justify the 2018 protective order. View "S.H. v. D.W." on Justia Law

The Supreme Court reversed the trial court's finding that Father's consent to the adoption of his child was irrevocably implied in this contested adoption proceeding, holding that a parent's implied consent to the adoption of a child may not be based solely on the parent's failure to appear at a single hearing.Grandparents filed a petition to adopt Child, claiming that Father's consent to the adoption was unnecessary. Father contested the adoption. But when Father failed to appear the morning of the final hearing in the adoption case, the trial court entered a decree of adoption, finding that Father's consent was not necessary. The Supreme Court reversed, holding that where Father appeared at the initial final hearing before it was rescheduled, responded to pleadings, and maintained communication with his attorney throughout the proceedings, the trial court erred in finding that Father's consent was irrevocably implied because of his failure to attend the final hearing. View "In re Adoption of C.A.H. v. R.S.E." on Justia Law

The Supreme Court affirmed the trial court's judgment in this action by an employer against several of its former employees and their new employer for alleged violations of the former employees' noncompetition and non-solicitation agreements, holding that the liquidated damages provisions in the employees' contracts were unenforceable and that there remained an issue of material fact precluding summary judgment as to the employer's tortious interference claims.The employer in this case brought claims against its former employees, including tortious interference with a contractual relationship and breach of contract claims. The trial court (1) granted summary judgment for the former employees on the issue of liquidated damages, finding that the liquidated damages provisions in the employees' contracts were unenforceable as a matter of law; and (2) found that there were issues of material fact regarding precluding summary judgment on the breach of contract claim. The Supreme Court affirmed, holding (1) the liquidated damages provisions were unenforceable penalties; and (2) an issue of material fact remained as to the employer's tortious interference with a contractual relationship claim. View "American Consulting, Inc. v. Hannum Wagle & Cline Engineering, Inc." on Justia Law

The Supreme Court vacated the section of the trial court's preliminary injunction purporting to enforce an unreasonable restrictive covenant in a noncompetition agreement, holding that parties to noncompetition agreements cannot use a reformation clause to contract around the principle that reviewing courts may delete, but not add, language to revise unreasonable restrictive covenants under Indiana's "blue pencil doctrine."Under the blue pencil doctrine, courts can make overbroad covenants reasonable by deleting language, but they may not add terms. The noncompetition agreement in this case contained an overbroad nonsolicitation covenant that contained a reformation clause authorizing the court to modify unenforceable provisions. The trial court granted a preliminary injunction enforcing the covenant. The court of appeals concluded that the nonsolicitation covenant was overbroad but revised the covenant to make it reasonable under the reformation clause. The Supreme Court granted transfer and held that since the nonsolicitation covenant could not be blue penciled, but rather required additional language to limit the scope of its restrictive covenants, it could not be enforced despite its reformation clause. View "Heraeus Medical, LLC v. Zimmer, Inc." on Justia Law

In these three judicial misconduct proceedings, the Supreme Court held that three judges engaged in judicial misconduct by appearing in public in an intoxicated state and behaving in an injudicious manner and by becoming involved in a verbal altercation.The Supreme Court issued a single opinion for all three cases because the misconduct charges stemmed from the same incident. The Indiana Commission on Judicial Qualifications filed charges against Respondents after an evening of drinking led to a physical altercation and two judges being shot. One judge was criminally charged and convicted after the altercation. Respondents agreed that their respective conduct violated several provisions of the Code of Judicial Conduct. The Supreme Court found that Respondents engaged in judicial misconduct and ordered that each judge be suspended from the office of judge without pay for thirty days. View "In re Honorable Andrew Adams" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court committing fifteen-year-old A.M. to the Department of Correction (DOC), holding that A.M. failed to demonstrate that he received ineffective assistance of counsel under the circumstances of this case.After a true finding of disorderly conduct, A.M. was placed on supervised probation. But due to A.M.'s conduct, the probation department recommended his placement with the DOC. After a disposition modification hearing, the juvenile court committed A.M. to the DOC for an indeterminate period. On appeal, A.M. argued that his attorney rendered ineffective assistance during the modification hearing. At issue in this case was whether the standard for deciding the claim was founded in the Sixth Amendment's right to counsel for a criminal proceeding or in the Fourteenth Amendment's due process clause. The Supreme Court held (1) a due process standard governs a child's claim that he received ineffective assistance in a disposition-modification hearing during his delinquency proceedings; and (2) A.M. received effective assistance of counsel during his modification hearing. View "A.M. v. State" on Justia Law

In this litigation arising from a transaction in goods governed by the Uniform Commercial Code (UCC) the Supreme Court affirmed the trial court order denying summary judgment, holding that there remained genuine issues of material fact precluding summary judgment.An agreement governing the sale of forty dump trucks contained a warranty and a one-year limitations period for filing a breach of contract suit. Buyers sued for breach of warranty several years later. The Supreme Court held (1) under the express terms of their agreement, the parties contracted for a future-performance warranty, and any breach of warranty claims did not accrue until the buyers knew, or should have known, of the breach; (2) under the equitable estoppel doctrine, a party's conduct may toll a contractually agreed-upon limitations period; and (3) in the instant case, genuine issues of material fact remained relating to the above two issues, precluding summary judgment. View "Kenworth of Indianapolis, Inc. v. Seventy-Seven Limited" on Justia Law

The Supreme Court affirmed the decision of the trial court terminating Mother's and Father's parental rights to seven children, holding that there was sufficient evidence to support the court's termination decision.After the trial court found the seven children to be children in need of services, Parents were ordered to complete services, and Father was ordered to complete sex-offender treatment. Father, however, never completed sex-offender treatment because Father refused to admit wrongdoing. The trial court subsequently terminated Parents' parental rights. On appeal, Mother and Father argued that the trial court violated Father's Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding that there was no constitutional violation because the court never ordered Father to admit to a crime and that the evidence supported the trial court's factual findings, which in turn supported its legal conclusions. View "M.H. v. Indiana Department of Child Services" on Justia Law

In this case concerning the State's civil complaint for forfeiture of Defendant's Land Rover the Supreme Court vacated the judgment of the trial court deciding that forfeiture of the vehicle would be grossly disproportional to the gravity of Defendant's dealing offense and established an analytical framework for courts to determine whether a punitive in rem forfeiture is an excessive fine.Specifically, the Court held (1) a use-based in rem fine is excessive if (a) the property was not an instrumentality of the underlying crimes, or (b) the property was an instrumentality but the harshness of the punishment would be grossly disproportional to the gravity of the underlying offenses and the owner's culpability for the property's misuse; (2) Defendant's Land Rover was an instrumentality of the underlying offense of drug dealing; and (3) the case requires a remand for the trial court to answer the question of gross disproportionality based on the framework set forth in this opinion. View "State v. Timbs" on Justia Law