Justia Indiana Supreme Court Opinion Summaries

Angela Martin and Brian Brothers co-hosted a house party at which alcohol was served. As the party was winding down, Brothers and two guests, Jerry Chambers and Paul Michalik, got into a fistfight. Martin found Michalik lying motionless on the basement floor and Chambers with blood on his face. The police later found Michalik dead outside the home. The personal representative of Michalik’s estate and Chambers’s bankruptcy trustee filed a complaint against Martin, alleging, in part, that she negligently caused Michalik’s injuries and that she furnished alcohol in violation of Indiana’s Dram Shop Act. The trial court granted Martin’s motion for summary judgment. The Supreme Court affirmed in part and reversed in part, holding (1) summary judgment on the negligence claim was improper, as there remained a question of fact as to whether Martin breached the landowner-invitee duty to exercise reasonable care for Michalik’s protection while he was on her premises; and (2) summary judgment was appropriate on Plaintiffs’ Dram Shop Act claim because Martin jointly paid for and possessed the same beer, and therefore, Martin could not “furnish” it to Brothers under the Act. View "Rogers v. Martin" on Justia Law

After a shooting that occurred at a bar, Plaintiffs filed a complaint against the bar alleging negligence. The trial court entered summary judgment in favor of the bar, concluding that the shooter’s criminal acts were unforeseeable, and therefore, the bar had no duty to anticipate and take steps to prevent the shooter’s conduct. The court of appeals reversed, declaring that reasonable foreseeability was not part of the analysis with respect to the bar’s duty. The Supreme Court granted transfer and affirmed the judgment of the trial court, holding (1) the trial court in this case employed a now-discarded analytical tool in determining the question of foreseeability; (2) in a negligence action, where foreseeability is an element of duty, this necessarily means the court must determine the question of foreseeability as a matter of law and must engage in a general analysis of the broad type of plaintiff and harm involved without regard to the facts of the actual occurrence; and (3) the trial court properly granted summary judgment in the bar’s favor because a shooting inside a neighborhood bar is not foreseeable as a matter of law. View "Goodwin v. Yeakle's Sports Bar & Grill, Inc" on Justia Law

Appellant pled guilty to possession of cocaine as a class D felony. In 2007, Appellant filed a pro se petition for post-conviction relief alleging ineffective assistance of counsel. The court summarily denied Appellant’s petition. In 2015, by counsel, Appellant filed a verified motion for leave to amend his petition for post-conviction relief and a verified motion for relief from the 2007 order that summarily denied his petition for post-conviction relief, arguing, inter alia, that his post-conviction petition was not referred to the State Public Defender and that his lack of education and cognitive deficiencies impacted his ability to represent himself. The post-conviction court determined that it would reinstate Appellant’s 2007 petition for post-conviction relief. The Supreme Court affirmed, holding that because Appellant’s 2007 petition for post-conviction relief was not referred to the State Public Defendant as required by the Post-Conviction Rules, and in light of Petitioner’s educational and cognitive deficiencies, the post-conviction court did not err in granting Appellant’s motion for relief from judgment so that he could seek meaningful post-conviction review. View "State v. Collier" on Justia Law

Defendant negligently struck Plaintiff’s vehicle, causing Plaintiff injuries that required medical treatment. Defendant admitted she was liable for the accident but contested the reasonable value of Plaintiff’s medical care. Before a trial on damages, Plaintiff moved to prevent the jury from hearing evidence that her providers accepted a reduced amount as payment in full. The trial court concluded that the payments were not permitted by Stanley v. Walker, in which the Supreme Court interpreted Indiana’s collateral-source statute to permit a defendant in a personal-injury suit to introduce discounted reimbursements negotiated between the plaintiff’s medical providers and his or her private health insurer, so long as insurance is not referenced. The Supreme Court reversed, holding (1) the rationale of Stanley v. Walker applies equally to reimbursements by government payers; and (2) the trial court misinterpreted Stanley by holding that the collateral-source statute required the exclusion of accepted reimbursements from government payers. Remanded. View "Patchett v. Lee" on Justia Law

After a jury trial, Defendant was convicted of murder, murder in the perpetration of criminal deviate conduct, and related crimes. The State sought a sentence of life without parole, but in the penalty phase, the jury was unable to reach a unanimous verdict as to whether the State had proven its charged aggravating circumstance. Nonetheless, the trial court sentenced Defendant to life imprisonment without the possibility of parole on the murder count. The Supreme Court remanded for a revised sentencing order as to the judge’s conclusion that life imprisonment was the appropriate sentence. On remand, the trial court affirmed the sentence. Defendant appealed, arguing, on grounds not previously raised, that the trial court’s imposition of a life sentence violated the Sixth Amendment because the aggravating factor supporting the sentence was not determined by the trier of fact during the penalty phase. The Supreme Court agreed, holding that the trial court committed reversible error by imposing a sentence of life without parole under the circumstances. In the interests of judicial economy, the Court further exercised its appellate prerogative to sentence Defendant to a term of years. View "Lewis v. State" on Justia Law

After a bench trial, Defendant was found guilty of Class B misdemeanor criminal mischief. After sentencing, the trial court held a separate hearing to determine the amount of restitution Defendant owed. The court ultimately concluded that Defendant owed $932 in restitution and that Defendant had the ability to pay in monthly installments of approximately $80. The restitution was ordered as a condition of Defendant’s probation. Defendant appealed the restitution order, arguing that it exceeded what he was able to pay in violation of Ind. Code 35-38-2-2.3(a)(6). The Supreme Court vacated the ordered restitution, holding that the restitution order was an abuse of discretion because the evidence was insufficient to conclude that Defendant had the ability to pay. View "Bell v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, robbery, and conspiracy to commit robbery. Defendant was sentenced to life imprisonment without possibility of parole. Defendant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) Defendant was not denied due process in discovery; (2) Defendant was not denied his right to a speedy trial; (3) the trial court did not abuse its discretion in denying Defendant’s requests to hire DNA and blood spatter experts at public expense; (4) the trial court did not commit fundamental error by allowing unknown witnesses to remain in the courtroom during opening statements despite a separation order; (5) the trial court did not abuse its discretion by allowing the State’s entomologist to testify; (6) the trial court properly admitted evidence found in Defendant’s van; and (7) sufficient evidence supported Defendant’s convictions. View "Griffith v. State" on Justia Law

Defendant pleaded guilty to one count of child solicitation as a Level 5 felony. The offense carried a sentencing range of one to six years, with three years being the advisory sentence. The trial court sentenced Defendant to the advisory sentence of three years, executed in the Department of Correction. Defendant appealed his sentence. The court of appeals ordered that Defendant be released from incarceration and serve the remainder of his three-year sentence on supervised probation, concluding that his fully-executed sentence was inappropriate under Indiana Appellate Rule 7(B). The Supreme Court granted transfer and affirmed the sentence imposed by the trial court, holding that the sentence imposed by the trial court did not warrant appellate revision and was not inappropriate under Rule 7(B). View "Bess v. State" on Justia Law

D.A. filed a petition for the expungement of several criminal conviction records. The trial court granted the petition and ordered the expungement of certain records related to D.A.’s convictions. Thereafter, Petitioner filed a second petition asking for the expungement of civil forfeiture records. The trial court denied the petition, concluding that the expungment statutes apply to arrests and criminal convictions but not to civil forfeitures. The Supreme Court affirmed the denial of D.A. second expungement petition, holding that Indiana’s expungement statutes do not reach civil forfeiture records. View "D.A. v. State" on Justia Law

Defendant and his wife were on the brink of divorce when Defendant screamed in his wife’s face and spat in her eye. Defendant was found guilty of B-misdemeanor disorderly conduct for knowingly or intentionally engaging in fighting and/or tumultuous conduct with his wife. Defendant appealed, arguing that the disorderly conduct statute requires both a public disturbance and a physical altercation and that the State failed to prove those elements. The Supreme Court affirmed, holding (1) the disorderly conduct statute’s “fighting” subsection does not contain a public disturbance element but does require a physical altercation; and (2) Defendant’s intentional spitting provided sufficient evidence of a physical altercation. View "Day v. State" on Justia Law