Justia Indiana Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of dealing in a narcotic drug within 1,000 feet of school property, a class A felony, and of being a habitual substance offender. The Supreme Court affirmed, holding (1) Defendant’s claim that he was a victim of “sentencing factor manipulation” was unavailing because “sentencing factor manipulation” was inapplicable to the charges against him; (2) Defendant waived his claim that the jury verdict was not unanimous; (3) the trial court did not err in admitting redacted letters Defendant wrote to potential witnesses from prison; (4) there was sufficient evidence to support the conviction; and (5) the trial court was within its discretion in ordering Defendant to serve a sentence of forty years for felony dealing. View "Bowman v. State" on Justia Law

After an adjudication determining that each of three children - N.G., L.C. and M.C. - was a Child in Need of Services, the Indiana Department of Child Services (DCS) filed petitions seeking the involuntary termination of the parental relationship between the children and their parents. The trial court granted the requested involuntary termination of the parental relationships. Mother appealed. The Court of Appeals reversed the termination of her rights as to L.C. and M.C. but affirmed as to N.G. The DCS sought transfer. The Supreme Court granted transfer and affirmed the trial court, holding (1) the trial court’s findings were supported by the evidence; (2) the trial court’s judgment terminating Mother’s parental rights and finding termination to be in the best interest of the children was supported by sufficient evidence; and (3) Mother’s due process claim was waived. View "A.C. v. Ind. Dep’t of Child Servs." on Justia Law

In this employment termination discrimination case, Plaintiff claimed, inter alia, that he had been harassed, discriminated, and retaliated against on the basis of his sex. The trial court granted summary judgment to Plaintiff’s former employer as to Plaintiff’s federal and state constitutional claims and as to Plaintiff’s retaliation claim under Title VII of the Civil Rights Act. The Court of Appeals affirmed. The Supreme Court granted transfer and summarily affirmed the decision of the Court of Appeals with respect to the federal and state constitutional claims. As to the retaliation claim, the Supreme Court held (1) to prevail on summary judgment on a claim for retaliation under Indiana procedural law, it is an employer’s burden to affirmatively negate the plaintiff’s claim, not the plaintiff’s burden to make a prima facie case of Title VII retaliation; and (2) the employer in this case satisfied its burden on summary judgment to affirmatively negate Plaintiff’s retaliation claim under Title VII of the Civil Rights Act. View "Gaff v. Indiana-Purdue Univ. of Fort Wayne" on Justia Law

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