Justia Indiana Supreme Court Opinion Summaries

In 2010, acting under the Government Modernization Act (GMA), the Town of Zionsville reorganized with the unincorporated areas of Eagle Township and all of Union Township. In 2013, the Town of Whitestown adopted an ordinance to annex certain territory in Perry Township. In 2014, the Perry Township adopted an ordinance proposing to reorganize with Zionsville. The Zionsville-Perry Reorganization plan was adopted by Zionsville and Perry Township in 2014. The Town of Whitestown sought judicial declarations that the Zionsville-Perry Reorganization plan was contrary to law. Zionsville counterclaimed, seeking a judicial declaration prohibiting Whitestown from pursuing its attempts to annex territory in Perry Township and Zionsville. The district court rejected the 2014 Zionsville-Perry Reorganization and approved Whitestown’s attempts to annex the territory in Perry and Zionsville, concluding that the 2014 Zionsville-Perry Reorganization was contrary to the GMA and therefore invalid. The Supreme Court reversed, holding that the 2014 Zionsville-Perry Reorganization was not prohibited and that Whitestown may not adopt annexation ordinances annexing territory in municipalities that are the result of completed reorganizations under the GMA. Remanded. View "Town of Zionsville v. Town of Whitestown" on Justia Law

Defendant was lawfully placed under arrest for driving without a valid driver’s license. Before the police officer placed Defendant in his police cruiser, he conducted a pat-down search of Defendant’s clothing to check for weapons. The officer discovered a pill container in Defendant’s pocket, opened the container, and found a single narcotic pill for which Defendant did not have a valid prescription. Defendant was charged with driving without a license and possession of a controlled substance. Defendant moved to suppress the evidence of the pill container’s contents, arguing that the officer’s opening of the pill contained was an unreasonable search. The trial court denied Defendant’s motion to suppress. The Supreme Court affirmed, holding that the opening of the pill container was within the scope of a search incident to a lawful arrest and reasonable under the Indiana Constitution. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of the murder of James Allen and the attempted murder of Gerald Beamon. Defendant appealed, arguing that the trial court erred in admitting Beamon’s testimony that Allen told Beamon he had shot Defendant the day before Allen’s murder. The court of appeals affirmed, concluding that the admission of the hearsay evidence was erroneous but harmless. The Supreme Court granted transfer on this issue, vacating that portion of the opinion below, and affirmed the admission of the hearsay testimony, holding that the statements fell within the hearsay exception of Ind. R. Evid. 804(b)(3), and therefore, the trial court did not err in admitting the challenged testimony on that basis. View "Beasley v. State" on Justia Law

Plaintiff brought several claims against multiple defendants arising out of his incarceration for a probation violation that occurred after his term of probation had expired. The trial court dismissed Plaintiff’s claims against all defendants. The court of appeals affirmed. Plaintiff sought transfer, contending that his claim against four individual probation officers under 42 U.S.C. 1983 was incorrectly dismissed for failure to state a claim. The Supreme Court granted transfer and reversed dismissal of Plaintiff’s section 1983 claim against the individually-named probation officers, holding that Plaintiff’s complaint stated a claim for relief under section 1983 against these defendants. View "Thornton v. State" on Justia Law

James Armour’s employment contract with AM General LLC entitled him to payment of a long-term incentive plan (LTIP). When Armour retired, he was to receive a lump sum LTIP payment, but instead he started receiving quarterly installment payments in the form of checks. AM General attempted to make the final installment payment with a subordinate promissory note. Armour rejected the Note and requested full payment. Thereafter, AM General filed a complaint seeking a declaratory judgment that it had not breached the LTIP portion of its agreement with Armour. Armour counterclaimed, asserting that AM General breached the employment agreement by failing to pay Armour the full LTIP payment when it was due and claiming that, by attempting to pay the remaining portion of the LTIP payment with a promissory note, AM General breached the duty of good faith and fair dealing. The trial court entered summary judgment in favor of Armour. The Court of Appeals reversed, finding a genuine issue of material fact with regard to how “payment” could be made under the LTIP provision of the agreement. The Supreme Court granted transfer and affirmed the grant of summary judgment, holding that AM General breached its employment agreement with Armour because the Note did not constitute payment under the employment agreement. View "AM General LLC v. Armour" on Justia Law

Plaintiff, an elementary school principal, was terminated after the school board learned that he had been involved in a sexual relationship with a teacher. Plaintiff filed a complaint against school defendants, alleging breach of contract and that the notice and procedure utilized by the school board in terminating his administrator’s contract denied him due process. The superior court granted summary judgment for the School. The Supreme Court affirmed, holding (1) the hearing process described in the teacher’s termination statute does not apply to termination of an administrator when his underlying teaching contract is not being terminated; (2) the language in Plaintiff’s form teacher’s contract referring to a hearing with the benefit of counsel and a just cause determination applies only to Plaintiff’s underlying teacher’s contract and not his administrator’s contract; and (3) under the circumstances of this case, Plaintiff received constitutional due process. View "Hewitt v. Westfield Washington Sch. Corp." on Justia Law

Davis Security Systems, LLC hired Donnell Caldwell as a security guard for the West Calumet Complex. Before his employment, Caldwell had been romantically involved with Stacy Knighten, a resident of the Complex. While on duty, Caldwell and Knighten were involved in an altercation, and Caldwell shot Knighten in the back, paralyzing her from the waist down. Knighten filed a complaint for damages against, among others, Davis Security under the theory of respondent superior. The trial court granted summary judgment in favor of Davis Security on all claims. The Supreme Court reversed the portion of the trial court’s order granting summary judgment in favor of Davis Security based on Knighten’s respondent superior claim, holding that the scope of Caldwell’s duties as an employee of Davis Security and the issue of whether in discharging his weapon Caldwell engaged in conduct consistent with his duties were matters that could not be resolved by summary disposition. Remanded. View "Knighten v. E. Chicago Housing Auth." on Justia Law

Plaintiff filed an application for insurance on his property, despite his property being vacant and uninhabitable. Based on the application, the insurance company issued a “Dwelling Fire Policy” on the property. Two months later, the property was destroyed by fire. The insurance company denied coverage and rescinded the policy because it contained material misrepresentations and false statements. Plaintiff filed suit against the company that issued the policy, the insurance agency, and the insurance agents, alleging that the agents made false representations as to the occupancy status of the house and committed forgery, deception, and insurance fraud. The trial court granted summary judgment for the agents and directed entry of judgments for all defendants. The Supreme Court (1) reversed in part the trial court’s entry of summary judgment for the agents to the extent that it may apply to Plaintiff’s claim for negligent procurement of insurance, holding that summary judgment was improperly entered on this claim; but (2) directed the entry of partial summary judgment for the agents as to Plaintiff’s claim alleging that the agents failed accurately to report dwelling fire policy information to the insurance company, holding that summary judgment was proper on this claim. View "Schmidt v. Indiana Insurance Co." on Justia Law

Wife and Husband divorced in 2007. Husband later filed a motion to modify spousal maintenance, arguing that maintenance should be revoked entirely because of Wife’s remarriage. The trial court denied Husband’s petition and ordered him to pay Wife’s attorney fees. The Court of Appeals reversed, concluding that Wife’s marriage to “a man of significant means” constituted a substantial change in her ability to support herself. The Supreme Court granted transfer and affirmed the trial court, holding (1) the trial court’s findings supported its judgment that Wife’s finances had not changed so substantially that revocation of maintenance was warranted; and (2) because the trial court’s award of maintenance is affirmed, so likewise is its award of attorney fees. View "Gertiser v. Stokes" on Justia Law

Defendant was a passenger in a vehicle that was stopped for not having a properly displayed license plate. The driver was placed under arrest for driving with a suspended license, and the police requested that Defendant exit the vehicle so an inventory search could be conducted. Upon exiting the vehicle, Defendant informed the police that he had a handgun in his pocket. Defendant was later found guilty of carrying a handgun without a license. Defendant appealed, arguing that the trial court erred in refusing to give his tendered final jury instruction on the defense of necessity. The Supreme Court reversed, holding (1) there was some evidence that warranted giving the defense of necessity instruction; and (2) it was error for the trial court to have refused giving the instruction. View "Hernandez v. State" on Justia Law