Justia Indiana Supreme Court Opinion Summaries

In Pfenning v. Lineman, the Supreme Court established that Indiana courts do not referee disputes arising from ordinary sports activity. The Court further held that, as a matter of law, when a sports participant injuries someone while engaging in conduct ordinary in the sport, and without intent or recklessness, the participant does not breach a duty. In this case, during a karate class drill, Defendant jump-kicked a bag, injuring Plaintiff, who was holding the bag. Plaintiff sued, alleging that Defendant negligently, recklessly, and unreasonably injured her. The trial court granted summary judgment for Defendant, concluding that, under Pfenning, Defendant breached no duty as a matter of law because the jump kick was “ordinary behavior” within the sport of karate generally. The court of appeals reversed. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed summary judgment, holding (1) under Pfenning, ordinary conduct in the sport turns on the sport generally, not the specific activity; and (2) because Defendant’s jump kick was ordinary conduct in the sport of karate generally and no evidence showed intent or recklessness, there was no breach as a matter of law. View "Megenity v. Dunn" on Justia Law

J.D.M. was adjudicated a delinquent for committing child molestation which, if committed by an adult, would constitute a Class C felony. The juvenile court ordered placement of J.D.M. at the Wernle Youth and Family Treatment Center. Prior to J.D.M.’s release from Wernle, the juvenile court issued an order that required J.D.M. to register as a sex offender. J.D.M. appealed, arguing that the statutory prerequisites for placing a juvenile on the sex offender registry were not met. The Supreme Court reversed the order requiring J.D.M. to register as a sex offender, holding that the juvenile court could not order J.D.M. to register as a sex or violent offender prior to his discharge from Wernle. Remanded. View "J.D.M. v. State" on Justia Law

In 2009, Carlton Curry was appointed as superintendent of Lawrence Utilities, the City of Lawrence’s municipally owned water and sewer utility. Just over two years later, Dean Jessup was elected as mayor of the City in the general election. Mayor Jessup terminated Curry after their differences in policy became apparent. Curry filed a complaint against the City, claiming he was wrongfully discharged under the utility superintendent statute, he was owned unpaid wages under the Wage Payment Statute, and the mayor tortiously interfered with his employment contract. The trial court (1) granted summary judgment in favor of Curry on the wrongful discharge claim, (2) granted summary judgment in favor of the City on the Wage Payment Statute claim, and (3) denied summary judgment on the tortious interference claim. The Supreme Court affirmed the trial court in all respects, holding (1) Mayor Jessup lacked authority to remove Curry as the utility service board superintendent; (2) Curry was not entitled to wages under the Wage Payment Statute; and (3) a genuine issue of material fact existed regarding Curry’s claim for intentional interference with an employment relationship. View "City of Lawrence Utilites Service Board v. Curry" on Justia Law

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