Justia Indiana Supreme Court Opinion Summaries

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

In this property dispute, the Supreme Court retained Indiana’s common-law rule prohibiting the unilateral relocation of fixed easements and affirmed the trial court’s entry of judgment for Joseph DeSpirito on his petition for judicial review and against Richland Convenience Store Partners, LLC (Richland) and the Town of Ellettsville, Indiana Plan Commission (Commission).Despite the opposition of DeSpirito, who owned an adjacent lot, the Commission approved Richland’s request to relocate a utility easement on its lot. On judicial review, the trial court granted summary judgment against Richland and the Commission, finding that DeSpirito had a fixed utility easement through Richland’s lot and that the easement’s fixed location meant it could not be changed by either party without consent of the other. At issue on appeal was whether the Court should adhere to Indiana’s longstanding common-law rule requiring all affected estate-holders to consent to the relocation of a fixed easement or to adopt the position of the Third Restatement of Property (Servitudes), which permits the unilateral relocation of easements if a court finds the proposed relocation is reasonable, consistent with the normal use and development of the servant estate, and does not adversely affect the dominant estate. The Supreme Court rejected the minority approach reflected in the Third Restatement and affirmed. View "Town of Ellettsville, Indiana Plan Commission v. DeSpirito" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Appellant’s petition for post-conviction relief alleging that his trial and appellate counsel were ineffective, holding that, although counsel made some mistakes, counsel’s performance was not deficient.Appellant was convicted of murdering two children and arson. The convictions were affirmed on appeal. Thereafter, Appellant sought post-conviction relief, alleging multiple instances of ineffective assistance by trial and appellate counsel. The trial court denied the petition. The Supreme Court affirmed, holding (1) counsel’s mistakes did not rise to the level of deficient performance pursuant to Strickland v. Washington, 466 U.S. 668 (1984); and (2) further, Appellant had not demonstrated that there was a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. View "Weisheit v. State" on Justia Law

In this property dispute between stepsiblings Brenda Sue Gittings and William Deal, the Supreme Court affirmed in part and reversed and remanded in part the judgment of the trial court, holding that William was not entitled to court approval of property transfers that led to his receipt of profitable land.Under the original terms of mirrored trusts that Brenda’s father and William’s mother created, the two stepsiblings were to share land and mineral interests placed in the trusts once both parents died. After Brenda’s father died, however, property transfers and amended trust terms resulted in William receiving all the land and mineral interests upon his mother’s death. When the land began generating income, William sought court approval of the property transfers. Brenda and her son responded with allegations challenging the property transfers and seeking affirmative relief. The Supreme Court held (1) the Gittingses’ assertions were subject to statutes of limitations to the extent they sought affirmative relief but not to the extent they diminished William’s request for declaratory relief; and (2) because the property transfers were improper, William was not entitled to court approval of the transfers. View "Gittings v. Deal" on Justia Law

The Supreme Court affirmed the trial court granting summary judgment in favor of Defendant on Plaintiff’s defective design claim, holding that, under the facts and circumstances of this case, Plaintiff’s misuse of a tool was the cause of his injuries and could not have been reasonably expected by Defendant, the tool’s manufacturer.In his complaint, Plaintiff alleged that the tool was defective in its design. Defendant filed a motion for summary judgment, arguing that the evidence established that Plaintiff misused the tool by failing to follow its directions. The trial court found that Plaintiff misused the tool and that he was at least fifty-one percent responsible for his injuries. The Supreme Court affirmed the trial court’s grant of summary judgment for Defendant, holding (1) the misuse defense serves as a complete defense; and (2) Plaintiff’s injuries could have been avoided had he followed the instructions, and Defendant could not reasonably expect that a consumer would misuse the tool in the manner that Plaintiff did. View "Campbell Hausfeld/Scott Fetzer Co. v. Johnson" on Justia Law

The Supreme Court accepted a certified question from the United States Court of Appeals for the Seventh Circuit and answered that online fantasy sports operators that condition entry to contests on payment and distribute cash prizes do not violate the Indiana right of publicity statute when those organizations use the names, pictures, and statistics of players without their consent.At issue was Indiana’s right of publicity statute, Ind. Code 32-36-1-8(a), which provides that “a person may not use an aspect of a personality’s right of publicity for a commercial purpose…without having obtained previous written consent.” Plaintiffs, collegiate student althetes, filed this class action complaint alleging that Defendants, DraftKings, Inc. and FanDuel, Inc., used their names and likenesses in operating online fantasy sports contest without their consent, in violation of their right of publicity. The district court dismissed the suit. Plaintiffs appealed, and the Seventh Circuit Court of Appeals certified a question of Indiana law to the Supreme Court. The Court answered that Indiana’s right of publicity statute contains an exception for “material that has newsworthy value” that includes online fantasy sports operators’ use of college players’ names, pictures, and statistics for online fantasy sports. View "Daniels v. FanDuel, Inc." on Justia Law

The Supreme Court affirmed the orders of the trial court setting aside the default judgment against certain defendants and denying Plaintiff’s motion to correct error, holding that the defendants made the requisite showing under Trial Rule 60(B)(1) of a meritorious defense.Matthew Joseph accidentally discharged a firearm while cleaning it, and the bullet struck Genia Wamsley, the occupant of the adjacent unit. Plaintiff, the personal representative of Genia’s estate, brought suit against the insurer of the apartment complex and its management company (collectively, Landlords) and Joseph. None of the defendants timely answered the complaint, and Wamsley was granted an entry of default judgment. Thereafter, Landlords moved to set aside the default judgment on grounds of excusable neglect. The trial court granted the motions and denied Plaintiff’s motion to correct error. The Supreme Court affirmed, holding that there existed “even slight evidence of excusable neglect.” View "Wamsley v. Tree City Village" on Justia Law

The Supreme Court affirmed the judgment of the trial court adjudicating B.T.E. a juvenile delinquent on two counts, including attempted aggravated battery, for plotting to shoot up and blow up his high school, holding that there was sufficient evidence to support the attempted aggravated battery conviction.B.T.E. took several steps to implement his plot to blow up his high school, targeting two of his classmates to die. The trial court adjudicated B.T.E. a delinquent for attempted aggravated battery and conspiracy to commit aggravated battery. On appeal, B.T.E. argued that there was insufficient evidence that he took the required “substantial step” toward committing aggravated battery under Indiana’s criminal-attempt statute, and instead, that his actions were “mere preparation.” The Supreme Court affirmed, holding that B.T.E.’s affirmative conduct amounted to a substantial step toward the commission of aggravated battery. View "B.T.E. v. State" on Justia Law