Justia Indiana Supreme Court Opinion Summaries

Defendant was convicted for refusing to identify himself to a law enforcement official. A majority of the court of appeals reversed, concluding that there was insufficient evidence to support the conviction. One judge dissented and would have affirmed the trial court. The Supreme Court granted transfer, thus vacating the judgment of the court of appeals. The Court agreed with the dissenting opinion and affirmed the judgment of the trial court, holding that the evidence was sufficient to support Defendant’s conviction under Ind. Code 34-28-5-3.5. View "Weaver v. State" on Justia Law

Respondent, Senior Judge William I. Garrard, was arrested and convicted for operating while intoxicated endangering a person. As a result of his conviction, the Indiana Commission on Judicial Qualifications brought a judicial disciplinary action against Respondent, contending that Respondent violated the Code of Judicial Conduct Rule 1.1 and Rule 1.2. Respondent agreed that he violated these rules. Respondent and the Commission agreed that, after assessing both the aggravating and the mitigating factors, the appropriate sanction was a public reprimand. The Supreme Court agreed with the parties and reprimanded Respondent. View "In re Hon. William I. Garrard" on Justia Law

Carol Jakubowicz and her two minor sons were involved in a car accident with Ronald Williams that resulted in injuries to the Jakubowiczs. Jakubowicz filed suit on behalf of herself and her sons against Williams. More than three years after the accident, Jakubowicz filed a motion for leave to amend her complaint and add an underinsured motorist (UIM) claim against State Farm, the Jakubowiczs’ insurer, stating that she believed Williams’ insurance policy would be insufficient to cover her damages. The trial court granted Jakubowicz’s motion for leave to amend. State Farm moved for summary judgment on the UIM claim, claiming it was barred because it was filed after the three-year limitation period in Jakubowicz’s insurance policy. The trial court denied the motion. The Supreme Court affirmed, holding that because the provision in the policy requiring an insured to bring suit within three years is in direct conflict with the policy’s requirement that State Farm will only pay if the underinsured motorist’s insurance has been exhausted, the policy is ambiguous and must be construed in favor of the insured. Remanded. View "State Farm Mut. Auto. Ins. Co. v. Jakubowicz" on Justia Law

Pursuant to 2011 amendments to statutes addressing collective bargaining for teachers and their employees, when parties failed to reach a collective bargaining agreement (CBA) regarding salaries and wages, the Indiana Education Employment Relations Board (IEERB) appoints a mediator. If the mediation fails, the parties must exchange their last best offers (LBOs). A factfinder appointed by the IEERB then selects which side’s LBO to adopt as the CBA. In this case, a teachers association appealed a factfinder’s decision to adopt a school’s LBO. The IEERB affirmed the factfinder’s decision. The Supreme Court affirmed, holding that the adopted LBO was collectively bargained and lawful. View "Jay Classroom Teachers Ass’n v. Jay School Corp." on Justia Law

Defendant was arrested and charged with several drug-related offenses. Defendant filed a motion to suppress all evidence seized as a result of a search of his home conducted without a warrant. The trial court largely denied the motion. After a jury trial, Defendant was found guilty of four drug-related counts. On appeal, Defendant argued that the police made a warrantless entry into his home without valid consent and that the police conducted an illegal protective sweep once inside. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress all evidence seized in the search of his home, holding (1) under the circumstances of this case, Defendant’s house guest, who answered the door to Defendant’s home, did not have the apparent authority to consent to police entry; and (2) because the police did not have a warrant or warrant exception to justify entry into Defendant’s home, the subsequent searches, including the protective sweep, were unlawful, and the fruits of those searches must be suppressed. View "Bradley v. State" on Justia Law

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