Justia Indiana Supreme Court Opinion Summaries

In the summer of 2022, two cousins, 17-year-old B.K. and 15-year-old S.K., visiting from Illinois, threw stolen fireworks into a Costco trash bin, causing a fire that resulted in property damage. The juveniles admitted to one delinquent act of criminal mischief each, while allegations of theft were dismissed by the State. Costco sought restitution for approximately $25,000, an amount initially considered by the State as “very unreasonable.” After a restitution hearing, the juvenile court issued a restitution order for $28,750, enforceable as a civil-judgment lien, holding the juveniles jointly and severally responsible for payment in full.The Court of Appeals affirmed the juvenile court's decision, holding that the restitution orders amount to enforceable judgment liens. The panel acknowledged that the governing statute does not expressly state that the restitution order is a judgment lien or that the juvenile court may enter the restitution order as a civil judgment. However, the court found the criminal restitution statute, which does consider a restitution order as a judgment lien, instructive.The Indiana Supreme Court reversed the lower court's decision, holding that the juvenile court lacked the authority to enforce its order as a civil-judgment lien. The court found that the juvenile restitution statute does not contain language that characterizes restitution as a civil judgment. The court also emphasized that Indiana courts must construe the juvenile code liberally to ensure that children within the juvenile justice system are treated as persons in need of care, protection, treatment, and rehabilitation. The court concluded that reading a judgment-lien provision into the Juvenile Restitution Statute runs counter to these statutory directives. The case was remanded for reconsideration of the restitution order in light of the court's holding. View "B. K. v. State of Indiana" on Justia Law

The case involves Illinois Casualty Company (ICC) and thirty-three models who contested whether arbitration was appropriate based on the assignment of several business insurance policies that ICC issued to B&S of Fort Wayne, Inc., Showgirl III, Inc., and Reba Enterprises, LLC (collectively, "Insured Clubs"). The models alleged that the Insured Clubs used their images for social media advertisements without their consent. The Insured Clubs had insurance policies with ICC, which they tendered for defense and indemnification. ICC denied coverage, leading to a settlement agreement between the Insured Clubs and the models, assigning the Insured Clubs’ rights against ICC to the models.The trial court compelled arbitration between ICC and the models. On appeal, the Indiana Court of Appeals reversed, finding that none of the models’ claims fell within the provision of the arbitration agreement. The models sought transfer to the Indiana Supreme Court.The Indiana Supreme Court held that an agreement to arbitrate in accordance with American Arbitration Association (AAA) rules constitutes “clear and unmistakable” intent to delegate arbitrability to an arbitrator. However, the court found that because no agreement to arbitrate existed between ICC and the Insured Clubs before 2016, the models could not compel arbitration for claims deriving from this period. The court affirmed in part and reversed in part, ruling that models with claims from 2016 and later could compel arbitration, but those with pre-2016 claims could not. View "Illinois Casualty Co. v. Burciaga" on Justia Law

In 1995, Jerry E. Russell Sr. was convicted of the murder of Pamela Foddrill, along with other crimes, and was sentenced to life imprisonment without parole (LWOP) plus 120 years. Russell appealed his sentence, which resulted in a modification of his sentences for criminal confinement and criminal deviate conduct, reducing his total sentence to LWOP plus 73 years. In 2003, Russell filed a Petition for Post-Conviction Relief (PCR), which was dismissed in 2019 in exchange for a resentencing hearing. The resentencing court upheld Russell's original sentence of LWOP plus 73 years.Russell appealed the resentencing order, arguing that he was intellectually disabled and therefore ineligible for an LWOP sentence, that his convictions violated double jeopardy protections, and that his sentence was inappropriate given the nature of the offenses and his character. The Indiana Supreme Court rejected all of Russell's arguments and affirmed the resentencing court's order. The court found that Russell had not proven that he was intellectually disabled, that his convictions did not violate double jeopardy protections, and that his sentence was not inappropriate given the nature of the offenses and his character. The court also found that Russell had not been denied due process during his resentencing hearing. View "Russell v. State of Indiana" on Justia Law

Duke Energy Indiana, a regulated electric utility, planned to build new facilities in Noblesville, Indiana, to meet increased customer demand. The project involved demolishing an abandoned house and garage and constructing a new substation, transmission lines, and a garage. The City of Noblesville insisted that Duke comply with its unified development ordinance before proceeding with the demolition, requiring Duke to obtain multiple permits. Duke declined, arguing that the city had no power to regulate a public utility's service-related projects through local permitting requirements. Despite not obtaining the permits, Duke began demolition.In response, Noblesville issued a stop-work order and sued Duke in the Hamilton Circuit Court seeking declaratory and injunctive relief to enforce its ordinance. Duke counterclaimed, arguing that Noblesville lacked jurisdiction and authority to regulate its activities. The trial court found in favor of Noblesville, ordering Duke to comply with the ordinance and obtain the permits. The court also imposed a $150,000 penalty against Duke for starting demolition without the required permits and awarded Noblesville $115,679.10 in attorneys’ fees, expert fees, and costs. The court of appeals affirmed the trial court's decision.The Indiana Supreme Court reversed the lower courts' decisions, holding that while the trial court had jurisdiction over Noblesville’s enforcement action against Duke, only the Indiana Utility Regulatory Commission could decide whether Noblesville’s ordinance interfered unreasonably with Duke’s utility functions. The court reasoned that the commission had both the fact-finding expertise and the broader non-local focus necessary to balance the competing interests of public utilities and municipalities in deciding such disputes. The case was remanded for further proceedings consistent with the court's opinion. View "Duke Energy Indiana LLC v. City of Noblesville" on Justia Law

The City of Carmel, Indiana, enacted two ordinances in 2019, one prohibiting the construction of above-ground utility lines unless authorized by the city, and another outlining procedures for relocating utility facilities due to city projects. The ordinances placed all costs on the utilities unless the city agreed otherwise. When the city began two improvement projects requiring Duke Energy to relocate its facilities underground, a dispute arose over who should bear the costs, estimated to exceed $500,000. The city filed a complaint with the Indiana Utility Regulatory Commission, asking it to uphold the ordinances as reasonable and order Duke to pay the relocation costs.The Commission, after a hearing, found the ordinances unreasonable and void. The city appealed this decision. The Court of Appeals reversed the Commission's order, dismissing the Commission as a party to the appeal. Both the Commission and Duke sought transfer to the Indiana Supreme Court.The Indiana Supreme Court affirmed the Commission's decision, finding that the Commission was a proper party on appeal and that its findings of fact were supported by substantial evidence. The court concluded that the ordinances were unreasonable because they threatened to impose unreasonable expenses on Duke, which would in turn impact all Duke customers throughout Indiana. The court also found that the Commission's order declaring the ordinances void was within its statutory power. View "City of Carmel v. Indiana Utility Regulatory Commission" on Justia Law

Abigail Fricke filed a Chapter 13 bankruptcy petition, which required her to disclose all her assets, including any lawsuits. Three years later, she filed a lawsuit against Red Lobster, alleging she was injured due to the restaurant's negligence. However, she did not update her bankruptcy asset schedule to include this lawsuit until after Red Lobster moved for summary judgment based on standing and judicial estoppel. The trial court denied Red Lobster's summary judgment motion, and the Court of Appeals affirmed.Red Lobster argued that Fricke lacked standing to sue because her personal injury claim was an asset that belonged to her bankruptcy estate rather than to her. The Indiana Supreme Court disagreed, stating that Fricke had standing to sue because she alleged a demonstrable injury allegedly caused by Red Lobster. The court clarified that while Fricke was improperly pursuing the claim on her own behalf rather than on behalf of the bankruptcy estate, this meant she was not the real party in interest, not that she lacked standing.Red Lobster also argued that judicial estoppel barred Fricke's claim. The court disagreed, stating that judicial estoppel did not apply when the bankruptcy court permits a plaintiff-debtor to cure their omission by amending their asset schedule to include a previously omitted lawsuit. The court found that Fricke did not mislead the bankruptcy court and did not prevail on a position in her bankruptcy proceedings that contradicts her claim in this state court negligence action. Therefore, her representations to the bankruptcy court did not judicially estop her from pursuing her personal injury claim against Red Lobster. The court affirmed the trial court's decision. View "Red Lobster Restaurants, LLC v. Fricke" on Justia Law

Six patients filed medical malpractice actions against the estate and practice of a deceased physician, alleging that the physician breached the standard of care. The patients submitted various materials to medical review panels, including a wrongful death complaint filed by the physician's wife in a separate malpractice action. The defendants petitioned the trial court to redact the wife's complaint and any mention of its contents from the patients' submissions. The trial court granted the petition.The case was appealed to the Indiana Court of Appeals, which affirmed the trial court's decision. The patients then petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court reversed the lower courts' decisions. The court concluded that trial courts do not have the authority to act as gatekeeper of the evidence a party submits to a medical review panel. The court also held that the third-party complaint in this case is evidence, and therefore, the trial court lacked the authority to order the patients to redact their submissions. The case was remanded for proceedings consistent with this opinion. View "Bojko v. Anonymous Physician" on Justia Law

The case involves an insurance claim filed by Christine and Roy Cosme after their insurer, Erie Insurance Exchange, cancelled their automobile insurance policy. The policy listed their son, Broyce Cosme, as a driver. The cancellation was due to a misunderstanding between Broyce and the Indiana Bureau of Motor Vehicles, which led to the suspension of Broyce's license. The Cosmes were informed that their policy would be cancelled unless they submitted a coverage-exclusion form removing Broyce from the policy. However, due to conflicting advice from their insurance agent at Churilla Insurance, the Cosmes did not submit the form before the deadline. The policy was cancelled, and shortly after, the Cosmes were involved in an accident with an uninsured motorist. Erie denied their claim, stating that their policy was no longer in effect at the time of the accident.The trial court granted a directed verdict in favor of Erie and Churilla, reasoning that the Cosmes brought about their own lack-of-coverage injuries when they failed to sign the exclusion form before the deadline. The court of appeals affirmed this decision, holding that the Cosmes failed to present sufficient evidence to support their claims against Erie and Churilla.The Indiana Supreme Court reversed the trial court's directed verdict for Erie, affirming as to Churilla, and remanded for further proceedings. The court held that at the directed-verdict stage, the court can review whether inferences from the evidence are reasonable, but it cannot weigh conflicting evidence or assess witness credibility. Applying this standard, the court found that the trial court erred in directing the verdict for Erie as the Cosmes’ case-in-chief presented sufficient (though conflicting) evidence to prove Erie breached its contract and violated its duty of good faith. However, the court correctly granted judgment to Churilla because the evidence showed Churilla owed no special duty to the Cosmes to procure insurance or advise on the insurance policy. View "Cosme v. Warfield" on Justia Law

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