Justia Indiana Supreme Court Opinion Summaries

After a bench trial, Defendant was convicted of two counts of murder and of being a serious violent felon in possession of a firearm. After a separate sentencing phase, the trial court sentenced Defendant to serve two life sentences without parole consecutively. After a subsequent sentencing hearing, the trial court imposed an additional twenty-year sentence for the firearm possession conviction, also to run consecutively. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in imposing consecutive life sentences; and (2) the trial court’s sentencing order was inadequate, but Defendant’s sentence was proper. View "Clippinger v. State" on Justia Law

Defendant was charged with operating a vehicle with an alcohol concentration equivalent (ACE) of 0.08 or more. At trial, the judge instructed the jury to presume Defendant’s ACE at the time of the offense based on a chemical test that was performed within three hours of his being stopped by law enforcement. The instruction told the jury it “shall presume,” yet also stated that “the presumption is rebuttable.” Defendant appealed, arguing that the instruction amounted to fundamental error because it improperly relieved the State of its burden to prove each element beyond a reasonable doubt. The Court of Appeals agreed and reversed Defendant’s conviction, concluding that the instruction did not make clear that the presumption was merely permissible. The Supreme Court granted transfer, thus vacating the opinion below, and affirmed, holding that the instruction did not unconstitutionally shift the State’s burden of proof in violation of Defendant’s due process rights. View "Pattison v. State" on Justia Law

Thomas Hale appealed his conviction for dealing in methamphetamine, on the sole grounds that the trial court abused its discretion in failing to grant him, at public expense, depositions of two State’s witnesses. After review, the Indiana Supreme Court found that prior precedent compelled the Court to agree with Hale and reverse his conviction. The Court took the opportunity of this case to provide guidance as to how trial courts should address such motions in the future. View "Hale v. Indiana" on Justia Law

In an effort to benefit from a growing customer base in Hamilton County, Ed Martin Toyota requested, and Toyota Motor Sales, U.S.A., Inc. planned to approve, that Ed Martin relocate from its Anderson, Madison County location, where it operated for several years, to the Fishers area. Prior to the move, Toyota informed its other new motor vehicle dealerships in the region, including Andy Mohr Toyota, Butler Toyota, and Tom Wood Toyota (“Dealers”), and it filed the relocation plan with the Auto Dealer Services Division of the Office of the Indiana Secretary of State (“Division”). Those three dealerships protested the relocation. The Auto Dealer Services Division dismissed their action for lack of standing—affirmed by the trial court, concluding the dealerships were outside the “relevant market area,” as defined by the Indiana Dealer Services Act. Finding that the Division's interpretation of that statutory definition was reasonable, the Supreme Court affirmed the Division's decision. View "Andy Mohr West v. Ind. Secretary of State, Auto Dealer Services Div." on Justia Law

David Allen (Father) and Kimberly Allen (Mother) divorced in 2002. The parties agreed to share custody of their two children, with Father paying child support to Mother. The parties’ settlement agreement and dissolution decree did not provide for payment of college expenses. In 2010, the parties agreed to an order whereby basic child support for their daughter, Hunter, was terminated, Father became responsible for Hunter’s undergraduate educational expenses, and Mother became responsible for providing Hunter’s health insurance. In 2013, shortly before Hunter’s 21st birthday, when Hunter was a senior at Indiana University, Father petitioned the court for modification of the agreed order. Father advised the court that Hunter was considering post-graduate education in dental school and Father requested, among other things, an order regarding Hunter’s graduate educational expenses. Specifically, he sought to have Hunter’s dental school expenses apportioned between him and Mother. The trial court ordered that the 2010 agreement between the parties was to remain in effect: Father continued to be responsible for education expenses, this time, the cost of dental school for Hunter (less any contribution from Hunter through grants, scholarship, loans, etc.); Mother was responsible for Hunter’s health insurance. Father appealed, arguing, among other things, that the trial court erred in not determining each parent’s presumptive share of educational expenses according to the Child Support Guidelines. Mother cross-appealed, arguing that the trial court did not have statutory authority to enter an educational award for graduate school expenses. The Court of Appeals reversed, agreeing with Father that the trial court erred by essentially making Father liable for all dental school expenses that Hunter did not otherwise cover. It rejected Mother’s cross-appeal argument that the trial court lacks authority to order parents to pay for their child’s graduate school expenses. After its review, the Indiana Supreme Court found that while the statutory provision at issue provided for payment of “postsecondary” educational expenses, the term postsecondary was undefined. The Court held that the term “postsecondary,” as used in the provision permitting an award for postsecondary educational expenses, did not include graduate or professional school expenses. The Court reversed the trial court's order that Father pay the costs of Hunter's dental school. View "Allen v. Allen" on Justia Law

Defendant was convicted of four traffic offenses related to his driving while intoxicated and his lack of a driver’s license. Defendant’s trial took place almost three years after his arrest. On appeal, Defendant argued that the trial court erred in denying his Ind. R. Crim. P. 4(C) motion for discharge for delay. Rule 4(C) provides that a defendant may not be held to answer a criminal charge for greater than one year except in certain circumstances. The Supreme Court reversed the denial of Defendant’s motion for discharge, holding that, under the circumstances of this case, Defendant was entitled to discharge pursuant to Rule 4(C). Remanded to the trial court to grant the motion pursuant to Rule 4(C). View "Allen v. State" on Justia Law

In 2014, the Town of Fortville adopted an ordinance and resolution annexing 644 acres (the “Annexation Territory”) of land adjacent to the municipality. A number of landowners (“Remonstrators”) comprising ninety-three percent of the owners of parcels within the affected area filed a petition challenging the proposed annexation. The trial court entered judgment in favor of the Remonstrators and ordered that the annexation shall not take place, concluding that the Annexation Territory was not needed and could not be used by the municipality for its development in the reasonably near future. The Supreme Court affirmed, holding (1) the trial court fulfilled its obligation to consider only whether the statutory conditions for annexation had been satisfied; and (2) the trial court did not clearly err in upholding the remonstrance and denying annexation because Fortville failed to demonstrate that the Annexation Territory was needed and could be used for Fortville’s development in the reasonably near future. View "Town of Fortville v. Certain Fortville Annexation Territory Landowners" on Justia Law

After a jury trial, Defendant was found guilty of domestic battery as a level 6 felony and battery as a level 6 felony. The level 6 battery conviction arose from Defendant’s assault on a woman whose brother had previously been married to Defendant’s aunt. The trial court sentenced Defendant to two years for each conviction to be served consecutively. The Supreme Court reversed the trial court’s judgment with respect to Defendant’s level 6 battery conviction, holding that the sister of a brother who was once married to Defendant’s aunt is not a “family or household” member within the meaning of the statute elevating misdemeanor battery to a level 6 felony. Remanded. View "Suggs v. State" on Justia Law

Eighty-three-year-old Geraldine Siner was admitted to Kindred Hospital in 2007 for treatment of aspiration pneumonia. Geraldine’s children, John Siner and Kathy Siner, later arranged for a transfer to Methodist Hospital. Upon her arrival, Geraldine required immediate treatment for a collapsed lung and was suffering from wounds on her cheeks, infection, and septic shock. Geraldine died twenty days later. The Siners filed a medical malpractice complaint against Kindred Hospital and Dr. Mohammed Majid, alleging that Defendants failed to comply with the appropriate standard of care, proximately resulting in injuries and damages requiring compensation. The trial court granted summary judgment in favor of Defendants. The Supreme Court reversed after noting that Defendants’ own designated evidence revealed conflicting medical opinions on the element of causation, holding (1) conflicting evidence on a material issue precludes a prima facie case for summary judgment; and (2) Defendants did not affirmatively negate the Siners’ claims as required to merit summary judgment. View "Siner v. Kindred Hosp. Ltd. P’ship" on Justia Law

Appellant pleaded guilty to two counts of murder, one count of class A felony robbery, and one count of class B felony burglary for crimes he committed when he was thirteen years old. Appellant was sentenced to an aggregate term of 170 years imprisonment. Beginning in 1991, Appellant attempted to obtain his trial court transcripts to prepare a petition for post-conviction relief (PCR), but his requests were denied until 2006 when the trial court ultimately granted Appellant’s request for transcripts. When he still had not received the transcript of the plea hearing, he withdrew his post-conviction relief petition. In 2010, Appellant moved to compel compliance with the trial court’s order for transcripts, but the trial court denied the petition because Appellant’s PCR petition had been withdrawn. In 2011, Appellant again filed a pro se PCR petition. In 2015, Appellant filed a petition for permission to file a belated appeal. The trial court denied the petition. Appellant now asked the Supreme Court to permit him to file a belated notice of appeal to appeal his sentence. The Supreme Court reversed, holding that, under the unique circumstances of this case, Appellant should be permitted to file a belated notice of appeal. View "Sanford v. State" on Justia Law