Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court granting Defendant's petition to modify her Class B felony sentence, holding that the trial court had no discretion to modify Defendant's sentence because Defendant's plea agreement called for a fixed sentence.In today's companion case, Rodriguez v. State, __ N.E.3d __ (Ind. 2019), the Supreme Court determined that the legislature's amendments to Ind. Code 35-38-1-17 did not signify a shift from the long-standing precedent of Pannarale v. State, 638 N.E.2d 1247 (Ind. 1994), in which the Court found that trial courts are bound by the terms of a plea agreement and may only modify a sentence in a way that would have been authorized at the time of sentencing. In the instant case, the trial court granted Defendant's petition to modify her sentence, which was imposed in accordance with the terms of a plea agreement. The Supreme Court reversed, holding that because Defendant's plea agreement called for a fixed sentence the trial court was bound by these terms and had no discretion to modify Defendant's sentence. View "State v. Stafford" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's petition to modify his sentence on the grounds that it was not authorized to modify the sentence imposed under Defendant's fixed-term plea agreement, holding that the decades-old rule that courts may modify a sentence only if a new sentence would not have violated the terms of the valid plea agreement had the new sentence been originally imposed remained undisturbed.Defendant petitioned to modify his sentence, arguing that recent changes to the modification statute supported the court's ability to modify his sentence. The State opposed the petition, arguing that courts have no power to modify a sentence once the court has accepted a binding stipulated plea agreement. The trial court agreed and denied Defendant's motion to modify his sentence. The court of appeals reversed, concluding that modification of Defendant's sentence was permissible. The Supreme Court granted transfer and affirmed the judgment of the trial court, holding that the legislature's amendments did not alter the settled law of Pannarale v. State, 638 N.E.2d 1247 (Ind. 1994), and its progeny, and therefore, the trial court properly found that it had no discretion to modify Defendant's sentence because it was bound by the terms of the valid plea agreement. View "Rodriguez v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of Class A misdemeanor domestic battery, holding that Defendant did not validly waive his right to a jury trial.In the underlying proceedings Defendant signed two advisement of rights forms. By the time he signed the second form the deadline to request a jury trial had passed. Neither form advised Defendant of the timeline to file a demand for a jury trial and that his failure to file a demand within that period would result in the waiver of his right. Further, the first advisement of rights did not inform Defendant that his demand for a jury trial had to be in writing. The Supreme Court held that Defendant did not validly waive his right to a jury trial. Because the evidence was sufficient to support the conviction, the Court noted that the State was free to retry Defendant. View "Dadouch v. State" on Justia Law

The Supreme Court affirmed the order of the Indiana Utility Regulatory Commission approving two complex, multi-year settlements regarding rates and infrastructure investments under the TDSIC Statute, Ind. Code ch. 8-1-39, holding that Appellant, a party to and proponent of the settlement agreements, was estopped from raising this challenge and that the Commission's order contained sufficient findings.The agreements in this case specified how, in the utility's period petitions to the Commission, rate increases should be calculated and allocated among the utility's various rate classes. Despite being a party to the underlying agreements, Appellant, a group of some of the utility's largest industrial customers, opposed the utility's second periodic petition. Specifically, Appellant argued that the utility's rate calculation and allocation based on the underlying agreements was contrary to the TDSIC Statute. The Commission largely approved the utility's petition. The Supreme Court affirmed, holding (1) Appellant was estopped from challenging the terms of the settlement; and (2) the Commission's conclusion was reasonable and properly supported by specific findings. View "NIPSCO Industrial Group v. Northern Indiana Public Service Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court ruling that Indiana's Civil Forfeiture Statute was constitutional, holding that the General Assembly may decide how and when forfeiture proceeds accrue to the "Common School Fund," which consists of, among other sources of revenue, "all forfeitures which may accrue."Indiana's Civil Forfeiture Statute, Ind. Code 34-24-1-4(d), directs the transfer of proceeds from seized property "to the treasurer of state for deposit in the common school fund." At issue in this case is whether the portion of the statute permitting the allocation of forfeiture revenue to reimburse law enforcement costs before these proceeds accrue to the Fund is constitutional under article 8, section 2 of the Indiana Constitution. The trial court concluded that the statute is constitutional. The Supreme Court affirmed, holding that article 8, section 2 permits the legislature to determine how and when forfeiture proceeds accrue to the Common School Fund. View "Horner v. Curry" on Justia Law

In these two consolidated cases, the Supreme Court held that, for the purposes of determining preferred venue pursuant to Trial Rule 75(A)(4), the actual principal office of an organization with a location in the State of Indiana, and not the location of the organization's registered agent, is the appropriate preferred venue.Here, two Court of Appeals opinions regarding preferred venue with in conflict with one another. The Supreme Court granted transfer and affirmed the trial court in one case and reversed the trial court in the other case, holding (1) a domestic organization's actual principal office and not the location of its registered agent is the appropriate preferred venue; and (2) in light of new business corporation statutes, the location of the registered agent no longer determines preferred venue for either domestic or foreign corporations. View "Morrison v. Vasquez" on Justia Law

The Supreme Court affirmed the finding of the trial court that five children were children in need of services (CHINS), holding that the doctrine of res judicata applies to bar a repeated filing of a CHINS petition based on evidence that could have been produced in the first filing but that the issue was not properly raised in the trial court in this case.The Department of Child Services (DCS) filed a petition alleging that the children in this case were CHINS but failed to present sufficient evidence of the parents' alleged substance abuse. The day after the trial court dismissed the case without prejudice DCS filed a second petition alleging the children were CHINS without any new or substantially different evidence. After the court considered evidence and testimony that could have been presented during the first proceeding, the court adjudicated the children CHINS. The Supreme Court affirmed, holding that the doctrine of res judicata was not properly raised in the trial court and that there was no fundamental error in the proceedings below. View "V.B. v. Indiana Department of Child Services" on Justia Law

The Supreme Court affirmed the decision of the trial court ordering state police officers to turn over to federal authorities a shipped box containing U.S. currency wrapped in multiple layers of sealed packaging that bore the odor of narcotics, holding that the totality of the circumstances established the requisite probable cause to believe the money was proceeds of drug trafficking.The shipped box in this case displayed hallmarks of parcels containing drugs and drug money. The officer sought and was granted a warrant authorizing a search of the package and seizure of proceeds of drug trafficking. Officers proceeded to open the box, and a canine alerted that the money contained therein, and not just the packaging surrounding it, contained the odor of narcotics. The officers then seized the cash and obtained a court order to turn it over to federal authorities. Appellant, the individual who shipped the parcel, argued on appeal that the seizure exceeded the scope of the warrant. The Supreme Court affirmed, holding (1) all the circumstances supplied a basis for probable cause to believe the cash was proceeds of drug trafficking; and (2) therefore, the seizure was lawful, and the trial court properly made its order transferring the property to the federal government. View "Hodges v. State" on Justia Law

The Supreme Court affirmed the verdict of the jury in Plaintiff's favor in this personal injury case, holding that an expert witness's professional licensure status and the reasons for professional discipline may be admissible to challenge the expert's credibility.Plaintiff was rear-ended by Defendant. The expert in this case was a doctor who testified that Plaintiff suffered permanent injury from the automobile accident. The trial court excluded evidence that the expert's medical license had previously been on probation and the reasons for the expert's past professional discipline. The jury found in favor of Plaintiff and awarded $1.3 million in damages. The Supreme Court affirmed, holding (1) the trial court abused its discretion when it excluded evidence that the expert's medical license had been on probation, but the error was harmless; and (2) the trial court properly excluded evidence of the reasons for the expert's professional discipline because that evidence was inadmissible under certain evidentiary rules. View "Tunstall v. Manning" on Justia Law

The Supreme Court held that International Business Machines, Corp. (IBM) was entitled to post-judgment interest on its $49.5 million damages award as entered by the trial court and affirmed by this Court in IBM I running from the date of the judgment on remand and not from the date of the original judgment in 2012.This case arose out of a contract entered into between the State, acting on behalf of the Family and Social Services Administration, and IBM to improve Indiana's welfare eligibility system. In IBM I, the Supreme Court determined that IBM materially breached the contract and remanded the matter to the trial court to determine damages and offsets. On remand, the trial court determined that damages to the State from the breach totaled $128 million and IBM was entitled to offsets in the amount of $49.5. Thus, IBM was ordered to pay the State $78.2 million, after offsets. On appeal, IBM argued, among other things, that it was entitled to post-judgment interest on the fees upheld by the Court in IBM I. The court of appeals agreed. The Supreme Court held that the post-judgment interest due to IBM ran from the judgment on remand and summarily affirmed the court of appeals on all other issues. View "International Business Machines Corp. v. State ex rel. Indiana Family & Social Services Administration" on Justia Law