Justia Indiana Supreme Court Opinion Summaries

In this Indiana Product Liability Act (IPLA) design-defect case, the Supreme Court held that the the trial court erred in determining that a component-part manufacturer owed no duty, as a matter of law, to install safety features that the injury party alleged were necessary.PACCAR, Inc. was the manufacturer of a glider kit, a component part that becomes an operable semi-truck after a purchaser installs an engine, exhaust system, and transmission. The glider kit has a blind spot behind it, and PACCAR did not include certain safety features to mitigate the danger created by the blind spot unless a customer specifically requested them. A driver backed up a semi with an integrated PACCAR glider kit and stuck and killed a construction foreman. His widow brought a design-defect claim against PACCAR, claiming that the lack of the safety features rendered the glider kit defective. The trial court granted PACCAR's motion for summary judgment, concluding that PACCAR owed no duty to install the safety features because the duly fell solely on the final manufacturer of the completed semi. The Supreme Court reversed and remanded for further proceedings, holding that whether PACCAR owed the decedent a duty to includes the features was a question for the trier of fact. View "Brewer v. PACCAR, Inc." on Justia Law

The Supreme Court granted transfer in this case to eliminate a residual double jeopardy violation not addressed by the court of appeals, holding that one of Defendant's remaining convictions must be reduced to a lesser included offense to eliminate the violation.Defendant was convicted of possession of cocaine, enhanced to a level four felony; possession of a narcotic drug, enhanced to a level five felony; and unlawful possession of a firearm by a serious violent felon and adjudicated a habitual offender. On appeal, Defendant argued that his conviction for firearm possession and the enhancements applied to the drug-related counts violated double jeopardy principles because they were based on the same evidence - his possession of a single firearm. The court of appeals affirmed Defendant's drug-related convictions but reversed and vacated the conviction and sentence for the firearm possession conviction. The Supreme Court held that because Defendant's two drug-related convictions were enhanced based on the same evidence of his possession of a single firearm, Defendant's conviction on possession of a narcotic drug must be remanded for entry of judgment as a level six felony. View "Springfield v. State" on Justia Law

In this municipal-annexation case, the Supreme Court affirmed the judgment of the trial court against the Town of Brownsburg, holding that a trial court hearing a remonstrance proceeding on judicial review must consider the evidence submitted by both the municipality and the remonstrators.In 2013, the Town adopted an ordinance to annex 4,462 acres of property adjacent to the Town. A group of affected landowners acting through a political action committee remonstrated, seeking a declaration that the Town did not meet the statutory annexation requirements. The trial court entered judgment for the Remonstrators and against the Town, determining that the Town had not met all statutory requirements for annexing the proposed territory. The Supreme Court affirmed, holding (1) on appellate review, the reviewing court asks not whether the record supports the municipality's decision to enact the annexation ordinance but whether it supports the trial court's decision to uphold or reject the annexation; (2) a trial court assessing the legality of a disputed annexation must equally weigh and balance the evidence submitted by both sides; and (3) the trial court did not satisfy its threshold burden to prove it met the requirements of either Ind. Code 36-4-3-13(b) or (c). View "Town of Brownsburg, Indiana v. Fight Against Brownsburg Annexation" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff's claims against Indiana-resident defendants without prejudice, holding that the trial court erred in basing its dismissal on lack of personal jurisdiction but that dismissal was nevertheless warranted on the record.The parties in this case entered into an independent contractor agreement that contained a forum-selection clause providing that the parties agreed to litigate their disputes in Texas. Plaintiff later brought suit in an Indiana circuit court alleging breach of contract and fraudulent inducement. Defendants moved to dismiss under Trial Rule 12(B)(2). The court court dismissed the complaint without prejudice, concluding that the Indiana trial court lacked personal jurisdiction over the Indiana-resident defendants because the parties agreed to litigate their dispute in Texas. The Supreme Court affirmed but on different grounds, holding (1) the forum-selection clause was mandatory and unambiguous in requiring that suit be brought in Texas; and (2) Plaintiff failed to satisfy its burden of showing that the clause was invalid. View "O'Bryant v. Adams" on Justia Law

The Supreme Court found that the Honorable Robert W. Freese, Judge of the Hendricks Superior Court 1, engaged in judicial misconduct and ordered that Judge Freese be suspended from the office of judge without pay for forty-five days.The Indiana Commission on Judicial Qualifications charged that Judge Freese's conduct violated four provisions of the Code of Judicial Conduct. The Supreme Court agreed, holding that Judge Freese engaged in judicial misconduct by appointing an unqualified friend as trustee of a trust and personal representative of a related estate, failing to disclose the friendship or a financial relationship with the friend, and failing to act promptly when faced with evidence of the friend's mismanagement and embezzlement of the funds entrusted to him. The Court concluded that a forty-five-day suspension from office was warranted under the circumstances. View "In re Honorable Robert W. Freese" on Justia Law

The Supreme Court affirmed the decision of the trial court granting Defendant's motion to suppress statements he made during an interrogation as inadmissible in his criminal trial, holding that there was substantial, probative evidence that Defendant was in custody at the time of the interrogation.Two police officers interrogated Defendant in a secured area at a police station without providing him with required Miranda warnings. In granting Defendant's motion to suppress, the trial court determined that the environment in which Defendant was interrogated was a "police setting." The Supreme Court affirmed, holding that the totality of the circumstances supported the trial court's conclusion that the interrogation was custodial. View "State v. Ruiz" on Justia Law

The Supreme Court affirmed the trial court's exercise of discretion to reconsider its initial appointment of the decedent's father as special administrator for the decedent's estate, holding that, though not required by statute or trial rule, courts should give notice and hold a hearing before appointing a special administrator or rescinding such an appointment.After Orlando Lewis, Jr. (Junior) died in a car crash, Orlando Lewis Sr. (Senior) was appointed special administrator to Junior's estate. Shana Toliver sought to remove Senior as special administrator of Junior's estate. Kathy Calloway also asked the trial court either to reconsider its appointment of Senior as special administrator or to remove him. The court ordered that it would reconsider and rescind its prior appointment of Senior as special administrator and appoint Toliver and Calloway as co-special administrators for Junior's estate. The Supreme Court affirmed, holding (1) the trial court could reconsider its prior appointment of Senior because the underlying matter was still pending; (2) the trial court did not abuse its discretion in reconsidering its appointment of Senior; and (3) an appointing or rescinding court should notify interested parties and hold a hearing. View "Lewis v. Toliver" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify his sentence, holding that Defendant needed the prosecutor's consent to modification before the court could modify his sentence, and because Defendant did not have that consent, his motion was properly denied.Defendant pled guilty to a Class C felony and two Class D felonies and was sentenced to eight years for the Class C felony and two years for each of the Class D felonies. After he was released on parole Defendant filed a motion to modify his sentence on the Class C felony, arguing that the terms of his sentenced placed an unnecessary burden on him as he strived to contribute positively to the community. The trial court denied the motion. The Supreme Court affirmed, holding that because Defendant was a "violent criminal," his motion to modify was governed by subsection (k), and because Defendant filed his motion more than one year after he was sentenced, he needed, but did not have, the prosecutor's consent to modification before the court could modify his sentence. View "Barber v. State" on Justia Law

The Supreme Court reversed the post-conviction court's order denying Appellant's motion to correct error and remanded this matter for further proceedings, holding that a post-conviction court abuses its discretion when it denies a party's legitimate request to make an offer of proof.Appellant was convicted of murder. When seeking post-conviction relief Appellant found himself sharing a holding cell with a man who provided information that, if true, would exonerate Appellant. Appellant's attorney attempted to secure the man's testimony, but obtaining the testimony was challenging. Appellant's counsel eventually sought leave from the court to get the testimony, but the post-conviction court refused to hear any argument from the attorney, even denying her the opportunity to make an offer of proof. After the court closed the evidence and Appellant's counsel attempted to make her case and develop a record for appeal, the court silenced her with threats of contempt. The Supreme Court reversed the post-conviction court's order denying Appellant's motion to correct error, holding that the post-conviction court abused its discretion by denying counsel the opportunity to make an offer of proof. View "Bedolla v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of dealing in a narcotic drug and resisting law enforcement, holding that the trial court did not commit fundamental error by allowing the State to present evidence of Defendant's post-arrest, pre-Miranda silence during trial.The court of appeals affirmed Defendant's conviction conviction, concluding that there was no error in using Defendant's post-arrest, pre-Miranda silence as substantive evidence against him during trial and that, even if there was error, it was not fundamental. The Supreme Court granted transfer and held (1) Defendant opened the door to the State's response that included comments about Defendant's post-arrest, pre-Miranda silence; and (2) even if the trial court erred in admitting the State's evidence and argument about Defendant's silence, the error was not fundamental for the reasons articulated in Owens v. State, 937 N.E.2d 880 (Ind. Ct. App. 2010). View "Kelly v. State" on Justia Law