Justia Indiana Supreme Court Opinion Summaries

The trial court found that the two minor children of Parents were “in need of services” under Ind. Code 31-34-1-1. Mother and Father filed separate notices of appeal challenging the child-in-need-of-services (CHINS) determination after the court held the dispositional hearing but before it entered the dispositional order. The court of appeals dismissed the appeal based on lack of jurisdiction on the grounds that Parents filed premature notices of appeal. The Supreme Court granted transfer and the trial court’s CHINS determination, holding (1) Parents’ premature notices of appeal did not deprive the court of appeals of jurisdiction to hear the appeal; and (2) on the merits, the trial court committed clear error in concluding that coercive intervention was required to ensure that the children were properly cared for. View "In re Matter of D.J." on Justia Law

Defendant pleaded guilty to two counts of attempted murder as class A felonies and two counts of attempted robbery resulting in serious bodily injury also as class A felonies. Defendant was sentenced to 100 years’ imprisonment with sixty years suspended to probation for an aggregate sentence of forty years executed. Defendant later filed a petition for post-convcition relief, arguing that his guilty plea was not entered knowingly, intelligently, and voluntarily, that the plea lacked a factual basis, and that the trial court erred in accepting the plea. The Supreme Court reversed, holding that Petitioner demonstrated by a preponderance of the evidence that the post-conviction court erred in denying his petition for relief because, at the time Petitioner entered the plea, he also professed his innocence. View "Ellis v. State" on Justia Law

Defendant was convicted of two counts of Class B felony burglary and adjudicated a habitual offender. The trial court sentenced Defendant to an aggregate sentence of thirty-three years. Defendant appealed, arguing that his sentence was inappropriate under Indiana Appellate Rule 7(B). The court of appeals affirmed. The Supreme Court granted transfer and revised Defendant’s sentences so that he received an aggregate sentence of sixteen years, holding that an aggregate sentence of thirty-three years was inappropriate in this case. In all other respects the Court summarily affirmed the Court of Appeals’ decision. View "Wampler v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder. Defendant was sentenced to life without parole. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court did not commit fundamental error when it did not find, sua sponte, that Defendant had an intellectual disability, precluding a life without parole sentence, even though Defendant's trial counsel withdrew the petition to determine whether he had the disability; (2) Defendant’s life without parole sentence was proportionate to the offense and thus did not violate Article 1, Section 16 of the Indiana Constitution; and (3) Defendant’s sentence was appropriate pursuant to Indiana Appellate Rule 7(B). View "Shoun v. State" on Justia Law

Kennedy Tank & Manufacturing Company contracted with Emmert Industrial Corporation to transport an enormous process tower vessel to Indiana to Tennessee. Despite several troubles resulting in unforeseen costs, Emmert successfully delivered the vehicle. When Kennedy refused to pay any additional charges, Emmert sued, alleging breach of contract and, in the alternative, unjust enrichment. Kennedy moved to dismiss Emmert’s complaint, arguing that the federal statute of limitations preempts Indiana’s longer limitations period. The trial court denied the motion to dismiss, finding no preemption. The Supreme Court affirmed, holding that Indiana’s statute of limitations is not preempted by the federal statute of limitations. View "Kennedy Tank & Manufacturing Co. v. Emmert Industrial Corp." on Justia Law

The State charged Defendant with two counts of unlawful possession of a firearm by a serious violent felon (SVF) and several other offenses. The SVF charges were based on the State’s allegation that Defendant had previously been convicted of second degree burglary in Ohio. After the trial court concluded that the Ohio statute and Indiana statutes on burglary were not substantially similar in regard to the elements of the offense, the trial court dismissed the two counts charging Defendant as an SVF. Thereafter, the State moved for mistrial on grounds it believed Defendant could not receive a fair trial because during voir dire the State had referred to the now-dismissed SVF courts. The trial court granted the motion. The State subsequently appealed the dismissal of the SVF counts. The court of appeals affirmed. The Supreme Court granted transfer and reversed the trial court, holding that the elements of Ohio’s second degree felony burglary statute are substantially similar to the corollary elements of Indiana’s level four felony burglary state, and therefore, the trial court erred in dismissing the informations charging Defendant as a serious violent felon. View "State v. Hancock" on Justia Law

In 2010, Father and Mother divorced. Mother later filed a motion for rule to show cause (contempt motion) alleging that Father should be held in contempt for failing to comply with the dissolution degree and a subsequent modification order regarding production of certain income and tax documents. Ultimately, the trial court found Father in contempt for failing to provide Mother tax documentation from 2010 forward pursuant to the parties’ dissolution decree. The court of appeals reversed the trial court for abuse of discretion because the court did not strictly comply with the rule to show cause statute and failed to give Father a way to purge himself of contempt. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding (1) the motion for the rule to show cause contained sufficient factual detail so as to excuse strict compliance and protect Father’s due process rights; (2) Father waived his objections to the evidentiary findings of the trial court, and the trial court’s factual determinations were supported by the evidence; and (3) the trial court was not required to give Father an opportunity to purge himself. View "In re Marriage of Reynolds" on Justia Law

Defendant was charged with felony possession. Defendant filed a motion to suppress, arguing that the police violated the Fourth Amendment and Article I, Section 11 of the Indiana Constitution when they opened his car door “to check on [Defendant’s] welfare.” The trial court denied the motion and, after a bench trial, convicted Defendant of misdemeanor possession of cocaine. The court of appeals affirmed, concluding that the police’s act of opening Defendant’s door was constitutionally permissible as a reasonable community caretaking function. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed, holding that the police’s warrantless search of Defendant was constitutionally permissible, as the officer had an objectively reasonable basis to open the door and check on Defendant’s well-being. View "Cruz-Salazar v. State" on Justia Law

Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law

In 2014, an investigative reporter with ESPN requested incident reports from the Notre Dame Security Police Department (Department) involving 275 student-athletes. The Department denied the request, asserting that Notre Dame was a private university, and therefore, its police department was not a “law enforcement agency” subject to Indiana’s Access to Public Records Act (APRA). ESPN filed suit, alleging that the Department had violated the APRA. The trial court granted judgment on the pleadings in favor of ESPN, finding that the Department was not a “law enforcement agency” under the APRA because it was not a “public agency.” The Supreme Court affirmed, holding that the Department is not a “public agency” subject to the APRA. View "ESPN, Inc. v. University of Notre Dame Police Department" on Justia Law