Justia Indiana Supreme Court Opinion Summaries

The hospital that paid out a doctor’s ownership interest after his employment as a cardiologist terminated did not breach its agreement with the doctor.Dr. Roderick Sawyer worked as a cardiologist for St. Vincent Medical Group, Inc. (the Medical Group) and was a member-owner of The Care Group Heart Hospital, LLC (the Hospital). Sawyer agreed with the Medical Group and the Hospital that upon “any termination” of employment between him and the Medical Group, his ownership interest in the Hospital must be discontinued and redeemed. After the Medical Group terminated Sawyer’s employment, the Hospital paid out Sawyer’s ownership interest. Sawyer sued the Hospital, among others, alleging breach of contract. The jury returned a verdict against the Hospital for breach of contract. The Supreme Court reversed, holding (1) under the plain meaning of the contract language, the Hospital did not breach the agreement by discontinuing and redeeming Sawyer’s ownership interest; but (2) the Hospital did breach the agreement by delaying the payout, so Sawyer was entitled to interest on the delay. View "Care Group Heart Hospital, LLC v. Sawyer" on Justia Law

The Supreme Court found that the Honorable Dean A. Young, a circuit court judge, engaged in judicial misconduct and ordered that Judge Young be suspended from office without pay for six days.The matter was before the Supreme Court on the report of the Special Masters appointed to hear evidence on the Indiana Commission on Judicial Qualifications’ notice of statement of charges against Judge Young. The allegations of judicial misconduct stemmed from a temporary restraining order that the judge heard and issued without adequate notice to the responding party or witnesses and while the judge had a specific interest in the matter. The Special Masters recommended, and the parties agreed, that the appropriate discipline was to suspend Judge Young for six days without pay. View "In re Honorable Dean A. Young" on Justia Law

The Supreme Court affirmed T.H.’s adjudication as a delinquent but remanded the case to the trial court to modify its records to show that T.H. committed an act that would be criminal mischief as a Class B misdemeanor.The State filed a petition alleging that T.H. committed a delinquent act that would be criminal mischief, a Class A misdemeanor, if committed by an adult. The trial court found that T.H. committed criminal mischief that caused at least $750 in loss, which would be a Class A misdemeanor, and adjudicated T.H. delinquent. The Supreme Court affirmed the adjudication but remanded the case, holding that no reasonable fact-finder could find the element of loss of at least $750 proven beyond a reasonable doubt. View "T.H. v. State" on Justia Law

Defendant pleaded guilty to attempted residential entry and resisting law enforcement. Defendant failed to appear at his sentencing hearing. Counsel moved for a continuance of the sentencing hearing, but the trial court denied a continuance. After a hearing held in Defendant’s absence, the court sentenced Defendant. Defendant appealed, arguing that the trial court abused its discretion in denying his motion to continue the sentencing hearing and that the maximum sentence on the attempted residential entry conviction was inappropriate under Appellate Rule 7(B). The court of appeals sua sponte reversed on other grounds. The Supreme Court granted transfer and affirmed, holding (1) the trial court did not abuse its discretion in denying a continuance; and (2) the sentence imposed by the trial court was not inappropriate under Appellate Rule 7(B). View "Robinson v. State" on Justia Law

At issue in this case was what constitutes sufficient evidence to prove a person intentionally or knowingly violated a protective order.K.G., the pastor of a small Indiana church, sought a protective order against Defendant, a parishioner. The court issued a protective order prohibiting Defendant from “harassing, annoying, telephoning, contacting, or directly or indirectly communicating with” K.G. After Defendant emailed three elders at the church, she was convicted of two counts of invasion of privacy for knowingly or intentionally violating the order. The jury found Defendant guilty. Defendant appealed, arguing that the evidence was insufficient to support the conviction. A majority of the Court of Appeals reversed, concluding that Defendant’s intent in sending the email was not to contact K.G. but to ask the church elders to discipline or punish K.G. for alleged wrongful conduct. The Supreme Court granted transfer and affirmed Defendant’s conviction, holding that the jury acted within its discretion in discrediting Defendant’s testimony and finding that Defendant intentionally or knowingly communicated with K.G. through her email. The court also affirmed Defendant’s sentence, holding that the trial court did not abuse its discretion by considering Defendant’s criminal history as an aggravating circumstance and that Defendant’s sentence was appropriate considering her offense and character. View "Phipps v. State" on Justia Law

At issue in this case was what constitutes sufficient evidence to prove a person intentionally or knowingly violated a protective order.K.G., the pastor of a small Indiana church, sought a protective order against Defendant, a parishioner. The court issued a protective order prohibiting Defendant from “harassing, annoying, telephoning, contacting, or directly or indirectly communicating with” K.G. After Defendant emailed three elders at the church, she was convicted of two counts of invasion of privacy for knowingly or intentionally violating the order. The jury found Defendant guilty. Defendant appealed, arguing that the evidence was insufficient to support the conviction. A majority of the Court of Appeals reversed, concluding that Defendant’s intent in sending the email was not to contact K.G. but to ask the church elders to discipline or punish K.G. for alleged wrongful conduct. The Supreme Court granted transfer and affirmed Defendant’s conviction, holding that the jury acted within its discretion in discrediting Defendant’s testimony and finding that Defendant intentionally or knowingly communicated with K.G. through her email. The court also affirmed Defendant’s sentence, holding that the trial court did not abuse its discretion by considering Defendant’s criminal history as an aggravating circumstance and that Defendant’s sentence was appropriate considering her offense and character. View "Phipps v. State" on Justia Law

Defendant, who was charged with voluntary manslaughter without also being charged with murder, was properly found guilty even where the State conceded the existence of sudden heat to support the standalone charge.On appeal, Defendant argued that the State was required to prove sudden heat and that the State’s concession rendered his self-defense defense illusory. The Court of Appeals reversed, ruling that the State failed to present sufficient evidence that Defendant acted with sudden heat. The Supreme Court granted transfer and affirmed the conviction, holding (1) although the jury was instructed that the State conceded the existence of sudden heat, there was evidence that Defendant acted in either sudden heat or self-defense, and therefore, the jury was presented with a classic question of fact; and (2) the State’s concession of sudden heat did not nullify Defendant’s claim of self-defense. View "Brantley v. State" on Justia Law

Defendant, who was charged with voluntary manslaughter without also being charged with murder, was properly found guilty even where the State conceded the existence of sudden heat to support the standalone charge.On appeal, Defendant argued that the State was required to prove sudden heat and that the State’s concession rendered his self-defense defense illusory. The Court of Appeals reversed, ruling that the State failed to present sufficient evidence that Defendant acted with sudden heat. The Supreme Court granted transfer and affirmed the conviction, holding (1) although the jury was instructed that the State conceded the existence of sudden heat, there was evidence that Defendant acted in either sudden heat or self-defense, and therefore, the jury was presented with a classic question of fact; and (2) the State’s concession of sudden heat did not nullify Defendant’s claim of self-defense. View "Brantley v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and conspiracy to commit murder and sentencing him to life imprisonment without parole for the murder conviction. The Supreme Court held (1) the State presented sufficient evidence to support Defendant’s convictions, and the court declined to reweigh the evidence; (2) the trial court did not commit reversible error in admitting certain evidence to which Defendant objected; and (3) Defendant’s life without parole sentence for murder was both constitutionally proportional and appropriate under Appellate Rule 7(B). View "McCallister v. State" on Justia Law

The boundary separating public trust land from privately-owned riparian land along the shores of Lake Michigan is the common-law ordinary high water mark (OHWM). Absent an authorized legislative conveyance, the State retains exclusive title up to that boundary.In this case, the trial court determined that the State holds title to the Lake Michigan shores in trust for the public and concluded that the private property interests at issue here overlap with those of the State. The Supreme Court affirmed in part and reversed in part, holding (1) Indiana, at statehood, acquired exclusive title to the bed of Lake Michigan up to the natural OHWM; (2) Indiana retains exclusive title up to the natural OHWM of Lake Michigan; and (3) at a minimum, walking along the Lake Michigan shore is a protected activity inherent in the exercise of traditional public trust rights. View "Gunderson v. State" on Justia Law