Justia Indiana Supreme Court Opinion Summaries

Dustin Lane, a defendant with a history of violent offenses, was serving a prison sentence for domestic battery against his ex-wife, A.N., when he violated a no-contact order by sending her ten letters. These letters, which ranged in tone from loving and apologetic to critical and accusatory, were seen as part of a cycle of manipulation and abuse. Lane was charged with ten counts of Class A misdemeanor invasion of privacy, one for each letter, and pleaded guilty to all counts. The trial court sentenced him to ten 300-day sentences, each to run consecutively, resulting in an aggregate 3,000-day sentence.On appeal, Lane argued that his sentence was inappropriate given the nature of his offenses and his character. The Court of Appeals agreed, finding the sentence inappropriate considering the nature of his offenses, and remanded the case with instructions to impose fully concurrent sentences for an aggregate 300-day term. However, a dissenting judge disagreed, noting Lane's history of violence and the manipulative nature of the letters.The Indiana Supreme Court granted transfer, vacating the opinion of the Court of Appeals. The court noted that Indiana Appellate Rule 7(B) permits reviewing courts to revise a criminal sentence that is “inappropriate in light of the nature of the offense and the character of the offender.” The court found that Lane's violent criminal history and the risk he posed of perpetuating the cycle of domestic abuse against A.N. warranted the lengthy sentence. The court affirmed the trial court's decision, emphasizing the importance of protecting victims and the community from offenders with a history of violence. View "Lane v. State of Indiana" on Justia Law

The case involves a civil forfeiture action initiated by the State of Indiana against $11,180 found during a search of Dylan Williams's apartment. Williams did not respond to the State's complaint, but his aunt, Angela Smith, intervened, claiming that she owned the money and that it was not connected to any criminal activity. The State argued that the money was tied to criminal activity, specifically drug offenses, based on its location and the denominations in which it was found. The trial court ruled in favor of the State, leading to an appeal by Smith.The case was initially heard in the Marion Superior Court, where the State seized the money and initiated forfeiture proceedings. After a hearing, the trial court ruled in favor of the State, leading to an appeal by Smith. The Indiana Court of Appeals affirmed the trial court's decision.The case was then reviewed by the Indiana Supreme Court. The court found that the State failed to establish a substantial connection between the seized money and any underlying offense. The court also noted that the State did not identify a specific, applicable offense that would subject the money to forfeiture. Furthermore, the court found that Smith presented uncontradicted evidence that the money belonged to her. The court therefore reversed the trial court's forfeiture order and ruled that the money must be returned to Smith. The court also clarified the procedural framework for when the State seeks forfeiture of money and who constitutes an "owner." View "Smith v. State of Indiana" on Justia Law

The case revolves around Sabrina Dunn, who was charged with murder after shooting her ex-husband, Bill Dunn, in her home. The couple had a history of domestic disputes, with Bill exhibiting erratic and abusive behavior, leading Sabrina to obtain multiple protective orders against him. Despite these orders, Bill continued to harass Sabrina, often breaking into her home. On the day of the incident, Bill entered Sabrina's home uninvited, carrying knives. Fearing for her life, Sabrina shot and killed him.The trial court instructed the jury that the State had to prove beyond a reasonable doubt that Sabrina did not act in self-defense “and/or” in defense of her dwelling. Sabrina was found guilty of murder and sentenced to a maximum term of sixty-five years. The Court of Appeals affirmed the conviction but revised the sentence to fifty-five years with five years suspended.The Indiana Supreme Court, however, found that the use of “and/or” in the jury instructions was ambiguous and potentially misleading. The court noted that the jury needed to understand that the State had to prove that Sabrina did not act in either self-defense or in defense of her dwelling. The ambiguous instructions, the court concluded, could have led the jury to believe that the State only needed to disprove one of these defenses, not both. Given the strength of Sabrina's defense-of-dwelling claim, the court found a serious risk that she was wrongly convicted. As a result, the court vacated Sabrina's murder conviction and remanded the case to the trial court for further proceedings. View "Dunn v. State" on Justia Law

In 2022, a delinquency petition was filed against G.W., a 17-year-old, alleging that he had committed acts that would be considered theft and criminal trespass if committed as an adult. G.W. admitted to one allegation of theft and one allegation of criminal trespass. After G.W. went missing and was later found in Mississippi, he was returned to Indiana for his dispositional hearing. The juvenile court rejected G.W.'s request for home detention and ordered wardship of G.W. to the Department of Correction (DOC). However, the court's dispositional order did not include specific findings to support G.W.'s commitment, as required by statute.The Court of Appeals affirmed the juvenile court's decision but acknowledged that the order failed to comply with the applicable statutory requirements. The panel remanded the case for an amended dispositional order which includes the written findings and conclusions required by the statute. After the Court of Appeals had delivered its decision, but before it had certified that decision, the juvenile court issued an amended dispositional order which included the required statutory findings.The Indiana Supreme Court held that when a juvenile court fails to enter the requisite findings of fact in its dispositional order, an appellate court should neither affirm nor reverse. Instead, the proper remedy is to remand the case under Indiana Appellate Rule 66(C)(8) while holding the appeal in abeyance. This process adheres to the applicable statutory requirements, preserves the distinct roles played by trial courts and appellate courts, and (in some cases) justifies the cost of juvenile detention. The court remanded the case to the juvenile court for entry of its amended dispositional order. View "G.W. v. State" on Justia Law

This case involved Safeco Insurance Company (Safeco) appealing against the trial court's dismissal of its third-party spoliation and negligence claims against the Michaelis Corporation. The dispute originated from a fire in a home insured by Safeco, which resulted in over $500,000 worth of damage. Safeco hired Michaelis to restore the property, and during this process, the kitchen, identified as the origin of the fire, was demolished and the dehydrator believed to have caused the fire was discarded. Safeco subsequently sued Michaelis for negligence and spoliation of evidence, arguing this impeded its ability to bring a successful claim against the dehydrator manufacturer.The trial court dismissed both claims, sparking Safeco's appeal. The Indiana Supreme Court held that under the given facts, Indiana common law did not recognize the tort of third-party spoliation and therefore upheld the trial court’s ruling. The court established that a special relationship did not exist between Safeco and Michaelis that would impose a duty on Michaelis to preserve the evidence. Furthermore, the court ruled it was not reasonably foreseeable that Safeco would be harmed by the loss of the dehydrator. Public policy considerations also weighed against recognizing third-party spoliation absent a special relationship.In addition, the court ruled that Safeco's negligence claim was essentially a third-party spoliation claim and failed for the same reasons. The court also dismissed Safeco's argument that Michaelis assumed a duty of care to preserve the evidence, as this was not alleged in the amended complaint and was raised for the first time on appeal. View "Safeco Insurance Company of Indiana v. Blue Sky Innovation Group, Inc" on Justia Law

The case pertains to a marital dissolution dispute in Indiana where the husband's police pension constituted the majority of the couple's marital estate. The husband was reluctant to share his pension with his wife, expressing his intention to disregard any court order mandating him to do so. As a response, the trial court ordered the husband to secure and subsidize a life insurance policy to ensure the wife received her share of the marital estate. The husband challenged the trial court's authority, arguing that the court did not consider the tax implications of his future pension payments.The Indiana Supreme Court upheld the trial court's decision. It ruled that the trial court had broad statutory authority to order a security or other guarantee, such as a life insurance policy, when necessary, to secure the division of property. The court also held that the husband had waived his challenge regarding the tax consequences of his future pension payments.The facts of the case reveal that the husband and wife had been married for nearly twenty-six years. The husband's police pension had a market value of over $1.1 million, constituting over 85% of the marital estate. The husband was unwilling to share his pension with his wife, and the wife expressed concern that she might not receive anything. The trial court ordered the husband to make monthly payments and obtain a life insurance policy that named her as owner and beneficiary. The husband contested this order, leading to the appeal. The Indiana Supreme Court affirmed the trial court's decision, maintaining that the court had the authority to secure the wife's share of the marital estate through a life insurance policy. View "Cooley v. Cooley" on Justia Law

This case before the Indiana Supreme Court concerns a juvenile, A.W., who was adjudicated for possession of a machine gun and dangerous possession of a firearm. The court was asked to determine if these adjudications violated the principle of double jeopardy under Indiana law. A.W. asserted that he did not know the firearm he possessed had been modified to function as a machine gun.The court found that A.W.'s exclusive possession of the modified gun, along with his abrupt flight from police, supported the conclusion that he knowingly or intentionally possessed a machine gun. This satisfied the first part of the court's inquiry.On the issue of double jeopardy, the court noted that while the Indiana Constitution could apply in juvenile proceedings, it avoided deciding that issue. Instead, it focused on whether possession of a dangerous firearm is a lesser-included offense of possession of a machine gun under the test set out in the case Wadle v. State. The court found that it was, meaning A.W.'s adjudications for both offenses violated his rights under the principle of double jeopardy. Therefore, the court affirmed the finding that A.W. knowingly possessed a machine gun but reversed the adjudication that he committed dangerous possession of a firearm. View "A. W. v. State of Indiana" on Justia Law

In a case before the Indiana Supreme Court, John Rust sought the Republican nomination for U.S. Senator for Indiana in 2024. Rust was concerned that he may be denied access to the primary ballot because he did not meet the state's Affiliation Statute's criteria. The Affiliation Statute required that a candidate either have voted for the party in the two most recent primary elections in which they voted or have party affiliation certified by the county party chair. Rust had not met either of these conditions. A lower court blocked enforcement of the law, deeming it unconstitutional.The Indiana Supreme Court reversed the lower court's ruling, finding that the Affiliation Statute was constitutionally sound. The court determined that the law imposed a minor, reasonable, and non-discriminatory restriction on Rust's First Amendment rights. It held that the law reasonably balanced the rights of candidates and parties, enabling the Republican Party to limit its candidates, protect its identifiability, and ensure stability in the political system. The court also rejected Rust's arguments that the law violated the Seventeenth Amendment, was vague and overbroad, improperly amended the Indiana Constitution, or allowed for invalid use of discretion under the Affiliation Statute. View "Morales v. Rust" on Justia Law

The Indiana Supreme Court vacated the theft convictions of Jennifer Teising, a former township trustee. Teising had been convicted on 21 counts of theft after she moved out of the township she represented and continued to collect her salary while working remotely. The court held that the state did not present sufficient evidence that Teising had the required criminal intent for theft, specifically that she believed she was not supposed to continue collecting her salary. Therefore, the court ruled that without criminal intent, the only available remedies were civil, such as a quo warranto action to remove Teising from office or a conversion claim to recover allegedly misappropriated money. View "Teising v. State of Indiana" on Justia Law

A fatal car crash led to a lawsuit against two Indiana restaurants that had served alcohol to the intoxicated driver responsible for the accident. The estate of the deceased sued the restaurants for negligence, arguing that they should have known the driver was visibly intoxicated and should not have allowed him to drive. The restaurants argued that the Indiana Dram Shop Act, which provides civil liability for establishments that serve alcohol to visibly intoxicated individuals who later cause injuries, eliminated any independent common-law liability. Therefore, they contended that the negligence claim should be dismissed.The Indiana Supreme Court held that the Dram Shop Act did not eliminate common-law liability, but rather modified it. The court ruled that claims against establishments that serve alcohol must still satisfy the requirements of the Dram Shop Act, namely that the server must have actual knowledge of the individual's visible intoxication, and that the individual's intoxication must be a proximate cause of the injury or damage. The court found that the estate's negligence claim met these requirements and therefore, the negligence claim was valid and could proceed. The court affirmed the lower court's decision to deny the restaurants' motion to dismiss the negligence claim. View "WEOC v. Adair" on Justia Law