Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the trial court’s grant of partial summary judgment on David Shaner’s claim for damages related to loss of consortium after his wife Laura’s death due to complications with the administration of dialysis treatments, holding that the wrongful death and survival statutes enable David’s claim to survive regardless of the existence of an heir.In his complaint, David sought two categories of damages contemplated by Indiana’s wrongful death statute: damages related to medical hospital, funeral, and burial expenses; and additional damages including loss of consortium, loss earnings and wages, and loss of additional employment benefits. David died during litigation, leaving no immediately ascertainable heirs. In moving for partial summary judgment on the loss of consortium claim, Defendants argued that any damages in excess of medical, hospital, funeral, and burial expenses would only serve to punish Defendants because the damages would pass to the State. The trial court granted the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that David’s claim for survivor damages could have survived regardless of the existence of an heir, and therefore, summary judgment on this claim was inappropriate. View "Horejs v. Milford" on Justia Law

The Supreme Court terminated the disciplinary proceedings relating to the circumstances giving rise to this judicial misconduct case, holding that continued litigation would be an inefficient use of judicial resources because the court over which Respondent presided no longer existed and because Respondent consented to a prohibition on future judicial service.The Supreme Court, however, wrote in order to clarify municipal courts’ power to administer infraction cases and infraction deferral agreements and to caution judicial officers on the impropriety of assuming the prosecutor’s duties. The Court then held (1) municipal courts’ status as “special courts” does not absolve them of the duties of a separate but co-equal branch of government; and (2) municipal court judges must endeavor to maintain, preserve, and protect the independence of Indiana’s judiciary even when administering the lowest-level civil and criminal offenses. View "In re Honorable Geoff L. Robison" on Justia Law

The Supreme Court reversed the decision of the Liability Administrative Law Judge (LALJ) concluding that Driver was Q.D.-A.’s employee under the Unemployment Compensation Act, holding that because Q.D.-A. proved the Act’s three part test, Driver was an independent contractor.Q.D.-A., which matches drivers with customers who need large vehicles driven to them, classified its drivers as independent contractors and did not pay unemployment taxes for them under the Act. The Act presumes a worker is an employee unless the employer proves three factors. Driver in this case filed for unemployment benefits under the Act, and the Department of Workforce Development classified Driver as an employee. The LALJ affirmed the Department’s classification. The Supreme Court reversed, holding that the LAJL unreasonably concluded that Driver was Q.D.-A.’s employee when Driver was not under Q.D.-A.’s control or direction, performed a service outside Q.D.-A.’s usual course of business, and ran an independently established business. View "Q.D.-A., Inc. v. Indiana Department of Workforce Development" on Justia Law

At issue in this case was whether to extend the holding in Tumulty v. State, 666 N.E.2d 394 (Ind. 1996) that a adult criminal defendant cannot challenge the validity of his guilty plea on direct appeal to an agreed delinquency adjudication. The Supreme Court held in this case that before Juvenile may pursue an appeal he must first seek relief from the trial court under Trial Rule 60(B).Specifically, the Supreme Court held (1) juveniles cannot immediately challenge on direct appeal any errors concerning their agreed adjudication, but because juveniles are not eligible for post-conviction relief, before pursuing their constitutional right to appeal, they must first assert any claims of error concerning their agreed judgment in a request for post-judgment relief filed with the juvenile court; and (2) juveniles who seek that relief in post-judgment proceedings have a statutory right to counsel under Ind. Code 31-32. View "J.W. v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court affirming the order of the Natural Resources Commission (NRC) finding that the Indiana Department of Natural Resources’ (DNR) use of a dam on Appellants’ property was proper, holding that the trial court properly enforced the order but that Appellants could, in the course of complying with the trial court’s order, modify their dam to remove it from the DNR’s jurisdiction under the Dam Safety Act, Ind. Code 14-27-7.5.Appellants had a large pond and related dam on their property. Since the early 2000s, the DNR attempted to exercise jurisdiction over the dam on the grounds that the dam was located in, on, or along a stream. Appellants contested DNR’s findings, largely without success, in administrative tribunals and the courts below. The Supreme Court affirmed, holding (1) the DNR’s definition of the word “stream” was reasonable, and Appellants had adequate notice of what constitutes a stream for purposes of the Dam Safety Act; (2) the DNR presented substantial evidence supporting its classification of Appellants’ dam as a high-hazard dam; and (3) Appellants could modify their dam to remove it from DNR’s future jurisdiction. View "Moriarity v. Indiana Department of Natural Resources" on Justia Law

Finding this to be a rare and exceptional criminal case, the Supreme Court reduced Defendant’s sentence pursuant to Appellate Rule 7(B), holding that the sentence imposed was inappropriate in light of Defendant’s offenses and character.Defendant pled guilty to multiple drug charges and admitted to being a habitual substance offender. The trial court sentenced Defendant to an aggregate sentence of thirty years to be served in the Indiana Department of Correction. The court of appeals affirmed. The Supreme Court granted Defendant’s petition to transfer and reduced Defendant’s sentence to the mandatory minimum of twenty-three years with the time remaining to be served in community corrections, holding that this was an exceptional case and that Defendant’s sentence was inappropriate given Defendant’s character and offenses committed. View "Livingston v. State" on Justia Law

The Supreme Court reversed the decision of the Tax Court determining that Richardson’s RV owed no Indiana sales tax because it took RVs it sold to certain out-of-state customers into Michigan before handing over the keys, holding that Richardson’s structured the Michigan deliveries solely to avoid taxes with no other legitimate business purpose.After an audit, the Department of Revenue issues proposed assessments to Richardson’s totaling nearly $250,000 in unpaid taxes and interest for the Michigan deliveries and deliveries to other states. The Tax Court granted summary judgment for Richardson’s, concluding that Indiana’s exemption statute did not apply to any of these transactions because, as a matter of law, the sales transactions at issue were not made ‘in Indiana.’” The Supreme Court reversed and remanded the case, holding (1) the Michigan deliveries were subject to sales tax because Richardson’s executed the Michigan deliveries solely to avoid paying Indiana sales tax with no other legitimate business purpose; and (2) the Tax Court must determine if the non-Michigan deliveries were taxable. View "Richardson's RV, Inc. v. Indiana Department of State Revenue" on Justia Law

The Supreme Court affirmed the order of the trial court granting Defendant’s petition for specialized driving privileges, holding that the proper venue for seeking relief when the petitioner “forfeits” driving privileges for life following a felony conviction for driving while suspended is the trial court in the petitioner’s county of residence.Petitioner, a resident of Adams County, was subject to a driver’s license suspension that was a lifetime forfeiture resulting from a felony conviction for driving while suspended as a habitual traffic violator. Petitioner petitioned the Adams Superior Court for specialized driving privileges (DSP), seeking relief that that suspension and two other suspensions. The superior court granted the SDP petition. The court of appeals reversed and remanded, holding that where the Noble Superior Court ordered the lifetime forfeiture, Petitioner was required to petition that court separately for SDP. The Supreme Court reversed, holding the lifetime forfeiture in this case was an administrative suspension rather than a court-ordered suspension, and therefore, Petitioner was required to seek relief in his county of residence rather than in the court that ordered the suspension. View "State v. Reinhart" on Justia Law

The Supreme Court affirmed Defendant’s conviction of murder and felony murder but remanded this matter for a more specific sentencing statement consistent with the dictates of Harrison v. State, 644 N.E.2d 1243, 1262 (Ind. 1995), holding that the sentencing statement did not meet the requirements of Harrison.Defendant pled guilty to the murder of Asenath Arnold and to felony murder for the death of Gary Henderson at the hands of Defendant’s accomplice. Defendant was sentenced to life without parole of the murder charge. The Supreme Court affirmed the convictions and sentence but remanded the matter for a new sentencing statement, holding (1) Defendant’s Miranda rights were not violated; (2) there was sufficient evidence to support the aggravating circumstance that made Defendant eligible for a life without parole sentence; (3) Defendant’s sentence of life with parole was appropriate; but (4) the sentencing statement did not comply with the dictates of Harrison. View "Schuler v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment finding Defendant guilty but mentally ill (GBMI), holding that the evidence led only to the conclusion that Defendant was insane when the crime was committed.Defendant was charged with murder. Defendant invoked the insanity defense and waived her right to a trial by jury. During the bench trial, three mental health experts testified that Defendant was legally insane at the time of the murder and could not appreciate the wrongfulness of her actions. The trial court rejected Defendant’s insanity defense and found Defendant guilty of GBMI, relying on evidence of Defendant’s demeanor in rendering its verdict. The court of appeals reversed, concluding that because of Defendant’s history of mental illness and the unanimous expert opinion, the demeanor evidence had no probative value. The Supreme Court vacated the court of appeals’ opinion and affirmed, holding (1) the fact-finder may discredit expert testimony and rely instead on other probative evidence from which to infer Defendant’s sanity; and (2) evidence of Defendant’s demeanor, taken together with the flaws in expert opinion testimony and the absence of a well-documented history of mental illness, supported the trial court’s rejection of Defendant’s insanity defense. View "Barcroft v. State" on Justia Law