Justia Indiana Supreme Court Opinion Summaries

In 2013, Defendant was charged with second degree murder for the death of a toddler that occurred in 1977. During a bench trial, the court admitted into evidence an autopsy report. The autopsy was performed by a pathologist who was unavailable to testify at trial. In addition to the autopsy report, the State called a forensic pathologist to testify regarding his independent opinion of the child’s death and injuries based on the autopsy report. The trial court found Defendant guilty of second degree murder. Defendant was sentenced to life imprisonment under the relevant sentencing statutes in 1977. The Supreme Court affirmed, holding (1) because the autopsy report was not testimonial, Defendant’s confrontation right was not violated when the report was admitted into evidence or when the surrogate pathologist testified regarding the information detailed in the autopsy report; (2) the delay between the murder of the child and Defendant’s prosecution did not violate Defendant’s due process rights; and (3) even if the trial court erred at sentencing by taking into consideration the current sentencing scheme that was inapplicable in this case, the error was harmless. View "Ackerman v. State" on Justia Law

Defendant was arrested for suspected murder. During Defendant’s pre-interrogation with his lawyer, police officers and a prosecutor eavesdropped as Defendant and his attorney discussed the location of evidence and defense trial strategy. Defendant was charged with murder. The officers involved in the investigation invoked the Fifth Amendment in response to all questions related to the eavesdropping, thus preventing Defendant and the court from learning the identity of the eavesdroppers and what they had overhead. Before trial, the trial court ordered blanket suppression of trial testimony from any witness who pleaded the Fifth. The State appealed the blanket suppression ruling. The Court of Appeals reversed the pretrial blanket suppression. The Supreme Court granted transfer, thereby vacating the opinion of the Court of Appeals, holding that prospectively imposing blanket suppression of all testimony from witnesses pleading the Fifth Amendment is inappropriate because a presumption of prejudice, rebuttable only by proof beyond a reasonable doubt, adequately protects Defendant from prejudice caused by the officers’ eavesdropping and their assertion of the Fifth Amendment privilege. Remanded for a determination as to whether the State has proven beyond a reasonable doubt an independent source for each presumptively tainted witness’s testimony without implicating the witness’s Fifth Amendment privilege and without derogating Defendant’s right of confrontation. View "State v. Taylor" on Justia Law

Defendant was convicted of class B felony dealing in methamphetamine (by delivery) (Counts I and II), one count of class B felony dealing in methamphetamine (by manufacture) (Count III), and one count of class D felony possession of precursors with intent to manufacture methamphetamine (Count IV). The sentences for Counts III and IV were imposed to run concurrently with each other but consecutive to the sentences on Counts I and II. Defendant received an aggregate sentence of thirty-two years. The Court of Appeals affirmed. The Supreme Court reversed Defendant’s sentences on Counts III and IV to run concurrently with his sentences on Counts I and II, for an aggregate sentence of sixteen years, holding that, under the particular circumstances of this case, the aggregate sentence of thirty-two years was inappropriate. View "Eckelbarger v. State" on Justia Law

In 2014, the General Assembly enacted Ind. Code 3-11-1.5-3.4 (the Statute), which created a Small Precinct Committee in Lake County and directed it to identify precincts with 500 active voters or fewer that may be amenable to consolidation. This measure was intended to reduce the cost of election administration in a county that contains more than fifteen percent of the State’s small precincts. Several precinct committeepersons sought declaratory judgment and an injunction, asserting that the Statute violated the State Constitution. The trial court concluded that the Statute is an impermissible special law and a violation of separation of powers principles. The Supreme Court reversed, holding (1) the Statute is constitutionally permissible special legislation; and (2) the Statute does not offend Indiana’s separation of powers clause. View "State v. Buncich" on Justia Law

The State and International Business Machines, Corp. (IBM) entered into a ten-year, $1.3 billion Master Services Agreement (MSA) to modernize and improve Indiana’s welfare eligibility system. The State terminated the MSA in less than three years, stating that performance issues on the part of IBM constituted a material breach of the MSA. Both parties sued each other for breach of contract. The trial court determined that the State failed to prove that IBM materially breached the MSA. The Supreme Court reversed the trial court’s finding that IBM did not materially breach the MSA, holding that, under the circumstances of this case, IBM’s collective breaches were material in light of the MSA as a whole. View "State v. Int’l Bus. Machines Corp." on Justia Law

After a jury trial, Defendant was convicted of murdering four people. Defendant was sentenced to life without parole for each of the four counts of murder, with the sentences to run consecutively. On appeal, Defendant challenged the sufficiency of the evidence to convict him of four murders. This appeal came directly to the Supreme Court because a sentence of life without parole was imposed. The Supreme Court affirmed the judgment of the trial court, holding that the State presented ample evidence that Defendant committed the four murders. View "Sallee v. State" on Justia Law

After a jury trial, Defendants, a married couple, were each convicted of involuntary manslaughter. After they were sentenced, Defendants filed a motion to correct error seeking a mistrial based on one juror’s affidavit describing the conduct of an alternate juror during the jury’s deliberations. The trial court denied the motion. The Court of Appeals affirmed the convictions. The Supreme Court granted transfer, consolidated the cases, and reversed the convictions, holding (1) the juror’s affidavit established that the alternate juror’s participation in jury deliberations was an external influence that pertained to the case, which showings resulted in a presumption of prejudice to Defendants; and (2) the State did not rebut the presumption by showing that the jury was nonetheless impartial, and therefore, a new trial is required. Remanded. View "Wahl v. State" on Justia Law

When Father and Mother initially divorced they had joint legal and physical custody of their minor child. The trial court subsequently granted an agreed order giving primary physical custody to Father. The parties continued to share joint legal custody. Later, Mother filed a petition for modification of custody and a verified motion for rule to show cause why Father should not be held in contempt for not complying with the court’s legal custody order. The trial court denied both of Mother’s requests. The court of appeals reversed, concluding (1) some of the trial court findings regarding the custody issue were erroneous, and (2) Father was in contempt for making unilateral decisions about the child’s education and by not sharing information with Mother. The Supreme Court vacated the court of appeals’ opinion, holding that the trial court did not err in denying Mother’s motions for custody modification and for contempt, as there was sufficient evidence to support the trial court’s determination that a custody modification was not in the child’s best interests and that Father’s failure to abide by the court’s legal custody order was not willful. View "Steele-Giri v. Steele" on Justia Law

Defendant was charged with twelve counts of various sex offenses. The charges arose from allegations made by three young girls. While Defendant was in jail awaiting his guilty plea hearing, he wrote an “intimidating and coercive” letter to the mother of one of the child victims. As a result of this letter, Defendant was charged with felony attempted obstruction of justice. The trial court found Defendant guilty of the charge and sentenced him to 600 days. The Supreme Court affirmed Defendant’s conviction and sentence for attempted obstruction of justice, holding (1) sufficient evidence supported the conviction; and (2) the trial court failed to properly consider Defendant’s participation in various program while incarcerated as a mitigating factor, but the error was harmless. View "McElfresh v. State" on Justia Law

Plaintiffs, two separate couples, brought suit seeking damages stemming from asbestos-caused diseases. Several Defendants in each case moved for summary judgment. In the first lawsuit, which led to two interlocutory appeals, the trial court denied Defendants’ motions for summary judgment. In the second lawsuit, the trial court entered summary judgment for Defendants as a final judgment. At issue in each appeal was the trial court’s ruling on a motion for summary judgment asserting the ten-year statute of repose included in Indiana’s Product Liability Act. In all three appeals, which the Supreme Court consolidated, Plaintiffs requested reconsideration of the Court’s prior holding in AlliedSignal v. Ott. The Supreme Court (1) declined to reconsider Ott’s holdings with respect to statutory construction due to the principles of stare decisis and legislative acquiescence; but (2) concluded that the Product Liability Act’s statute of repose did not bar Plaintiffs’ claims, as the Act’s statute of repose does not apply to cases such as these where the plaintiffs have had protracted exposure to inherently dangerous foreign substances. View "Myers v. Crouse-Hinds Div. of Cooper Indus., Inc." on Justia Law