Justia Indiana Supreme Court Opinion Summaries

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

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