Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with two D-felony counts of strangulation and two counts of domestic battery, one of which was elevated to a D-felony based on a prior domestic battery conviction. Defendant moved to bifurcate the D-felony domestic battery charge. The jury found Defendant guilty of the misdemeanor domestic battery and not guilty of the strangulation charges. The judge then asked Defendant’s counsel whether Defendant would like to waive his right to a jury trial on the D-felony domestic battery charge. Defendant remained silent while his attorney told the judge that Defendant intended to proceed as a bench trial on the second phase of the bifurcated trial. After a bench trial on the second phase Defendant was found guilty of the D-felony domestic battery. Defendant appealed, arguing that he did not validly waive his state and federal constitutional jury trial rights. The Supreme Court reversed Defendant’s conviction for D-felony domestic battery, holding that the trial court committed fundamental error by proceeding to trial absent personal waiver of his constitutional jury trial right by Defendant himself. Remanded for a new trial. View "Horton v. State" on Justia Law

The Energy and Policy Institute made three separate requests to Indiana House Representative Eric Koch under the Indiana Access to Public Records Act (APRA) seeking copies of Koch’s correspondence with various business organizations in relation to specific legislation. The Chief Counsel of the Republic Caucus denied each of these requests. Plaintiffs subsequently filed a complaint against Koch and the Indiana House Republic Caucus seeking a declaratory judgment that APRA was applicable to Defendants and that Defendants violated APRA by denying some or all of Plaintiffs’ requests. Defendants filed a motion to dismiss for lack of justiciability and, alternatively, for failure to state claim, arguing that Plaintiffs’ requests would interfere with the internal workings of the legislature and should be found non-justiciable on those grounds. The trial court granted Defendants’ motion to dismiss. The Supreme Court affirmed, holding (1) the question of whether the APRA is generally applicable to the legislature is justiciable, and the APRA does apply to the General Assembly; but (2) the question of whether the APRA requests at issue in this case are exempt from disclosure as legislative “work product” is non-justiciable. View "Citizens Action Coalition of Ind. v. Koch" on Justia Law

In 2014, the Indiana Department of Child Services (DCS) filed a petition alleging that M.B., a minor child, was a child in need of services (CHINS). While the CHINS case was still pending, M.B.'s paternal aunt and uncle (Aunt and Uncle) filed an independent action seeking custody of M.B. The trial court dismissed the action, concluding that Aunt and Uncle did not have standing to bring an independent custody action and that the circuit court did not have jurisdiction to hear the independent custody matter while the CHINS case was pending in the juvenile court. The Supreme Court reversed, holding (1) Aunt and Uncle had standing to bring the independent custody action; and (2) the circuit court had subject matter jurisdiction over the independent custody action but should have stayed the proceedings and abstained from exercising its jurisdiction until the CHINS action concluded. Remanded to the circuit court. View "In re Custody of M.B." on Justia Law

After a jury trial, Defendant was found guilty of battery as a class A misdemeanor. Under the provisions of Ind. Code 35-38-1-7.7(a), the trial court also determined that Defendant committed a crime of “domestic violence,” which determination rendered Defendant ineligible to possess a firearm. Defendant appealed, arguing, in part, that the firearm restriction amounted to additional punishment above the statutory maximum for misdemeanor battery, and because the facts supporting the enhancement were not submitted to a jury, the determination violated Defendant’s Sixth Amendment right to trial by jury. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to trial by jury; and (2) the evidence was sufficient to sustain the determination that Defendant committed a crime of domestic violence. View "Hitch v. State" on Justia Law

Defendant pleaded guilty to murdering Stephanie Kirk. Following a sentencing hearing, the trial court sentenced Defendant to death. Defendant appealed his death sentence. The Supreme Court affirmed, holding (1) there was sufficient evidence to prove beyond a reasonable doubt that Defendant murdered Kirk while committing criminal deviate conduct; (2) the trial court did not commit fundamental error when it allowed the State to amend the charging information; (3) the trial court did not abuse its discretion in weighing the aggravating and mitigating circumstances in sentencing Defendant to death; and (4) Defendant’s sentence was not inappropriate in light of the nature of his offense and what the record revealed about his character. View "Gibson v. State" on Justia Law

In 2005, Indianapolis passed a non-smoking ordinance (“Ordinance”) banning smoking in public businesses but providing certain exemptions. A 2012 amendment removed the exemption for bars and taverns that had liquor licenses and neither served nor employed anyone under the age of eighteen. The amendment, however, exempted businesses licensed as satellite gambling facilities by April 1, 2012. Plaintiffs, certain bars and restaurants, claimed the Ordinance violated the Equal Privileges and Immunities Clause of the Indiana Constitution because it applied to them but exempted satellite gambling facilities. The trial court granted summary judgment for Defendants, concluding that the Ordinance’s exemptions were not unconstitutional. The Court of Appeals reversed and severed the satellite facility exemption, concluding that the Ordinance’s exemption for satellite facilities violated the Equal Privileges and Immunities Clause. The Supreme Court granted transfer and affirmed the trial court’s grant of summary judgment in favor of the City, holding that the Ordinance does not violate the Indiana Constitution’s Equal Privileges and Immunities Clause because the exemption for satellite gambling facilities is reasonably related to the inherent differences distinguishing satellite gambling facilities from bars and restaurants and because the Ordinance does not create a monopoly or treat similarly situated classes disparately. View "Whistle Stop Inn, Inc. v. City of Indianapolis" on Justia Law

In 2005, Indianapolis passed a non-smoking ordinance (“Ordinance”) banning smoking in public businesses but providing certain exemptions. A 2012 amendment removed the exemption for bars and taverns that had liquor licenses and neither served nor employed anyone under the age of eighteen. The amendment, however, exempted businesses licensed as satellite gambling facilities by April 1, 2012. Plaintiffs, certain bars and restaurants, claimed the Ordinance violated the Equal Privileges and Immunities Clause of the Indiana Constitution because it applied to them but exempted satellite gambling facilities. The trial court granted summary judgment for Defendants, concluding that the Ordinance’s exemptions were not unconstitutional. The Court of Appeals reversed and severed the satellite facility exemption, concluding that the Ordinance’s exemption for satellite facilities violated the Equal Privileges and Immunities Clause. The Supreme Court granted transfer and affirmed the trial court’s grant of summary judgment in favor of the City, holding that the Ordinance does not violate the Indiana Constitution’s Equal Privileges and Immunities Clause because the exemption for satellite gambling facilities is reasonably related to the inherent differences distinguishing satellite gambling facilities from bars and restaurants and because the Ordinance does not create a monopoly or treat similarly situated classes disparately. View "Whistle Stop Inn, Inc. v. City of Indianapolis" on Justia Law

In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

Plaintiff fell and injured herself when she stepped into a hole on one of the streets in Beech Grove City, Indiana. Plaintiff subsequently filed a negligence complaint against the City. The City asserted that it was immune from liability under the Indiana Tort Claims Act’s (ITCA) discretionary function immunity provision. The Supreme Court affirmed, holding that, based on a review of the designated evidence and the Court’s existing precedent, the City was not entitled to summary judgment on the question of discretionary function immunity under the ITCA because the City did not demonstrate that the challenged act or omission was a policy decision made by consciously balancing risks and benefits. View "City of Beech Grove v. Beloat" on Justia Law