Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court finding that Father committed an act of domestic or family violence against Child and that he represented a credible threat to the family's safety and thus granting Mother's petition for an ex parte petition order, holding that the trial court's evidence-based findings supported its judgment.Specifically, the Supreme Court held (1) the evidence presented supported the trial court's finding that Father committed an act of domestic or family violence; and (2) Mother presented probative evidence to support the trial court's finding that Father posed a credible threat to Mother or Child's safety. View "S.D. v. G.D." on Justia Law

The Supreme Court affirmed the judgment of the trial court excluding the opinion testimony from three of Defendant's family members regarding the victim's untruthful character, holding that the trial court erred in excluding the opinion testimony but that the error was harmless.Defendant was charged with several felony child molestation counts and one count of felony incest for molesting his minor daughter. Before trial, Defendant requested to call three relatives as witnesses to testify about the opinion of the victim's character for untruthfulness. The trial court excluded the testimony on the grounds that Defendant had not established a proper foundation. After trial, the jury found Defendant guilty of felony child molesting. The Supreme Court affirmed, holding that the trial court erred in excluding the testimony of one witness for lack of foundation, but the error was harmless. View "Hayko v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing a Monroe County action with prejudice and denying Appellant's motions to correct error and to amend her complaint, holding that a plaintiff seeking tort damages from both government and non-government defendants must sue all such tortfeasors in one lawsuit.Plaintiff sustained injuries while driving in an I-69 construction zone. Plaintiff obtained a judgment against a non-government defendant in Lake County to satisfy the requirements for obtaining insurance coverage. After Plaintiff and the insurer settled her insurance claims Plaintiff again sued for the same injuries, this time in the Monroe Circuit Court against six other defendants, both government and non-government. The trial court dismissed the action with prejudice, concluding that collateral estoppel and claim splitting barred Plaintiff's claims. The Supreme Court affirmed, holding (1) the trial court was correct in dismissing Plaintiff's action on issue preclusion grounds; and (2) Plaintiff was not entitled to relief on her remaining claims of error. View "Davidson v. State" on Justia Law

The Supreme Court dismissed this appeal from a decision of the court of appeals requiring Adoptive Parents to provide notice to biological Father of the temporary custody of Child, rending the trial court's temporary custody order void for lack of personal jurisdiction, holding that this Court lacked appellate jurisdiction.After Child was placed full-time with Adoptive Parents, Adoptive Parents petitioned to adopt child and separately moved for temporary custody. Father was not served the petition or motions. After a hearing, the superior court granted Adoptive Parents temporary custody, determining that it was in Child's best interests while the adoption petition was pending. Father later filed a motion to set aside the order of custody on the grounds that he was not given notice. The trial court denied the motion. Adoptive Parents appealed. The Supreme Court dismissed the appeal, holding that the superior court's order granting temporary custody was not a final judgment because it neither disposed of all claims for all parties nor stated that there was no just reason for delay. View "P.L. v. A.H." on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, felony robbery resulting in serious bodily injury, and two counts of criminal confinement and his sentence of life without parole for the murder conviction, holding that Defendant was not entitled to relief on his allegations of error.Defendant, a gang leader, supervised and participated in the torture and brutal killing of member of the gang that other members believed was a police snitch. Once the victim was dead, Defendant oversaw cleaning up the crime scene and then hid the body. The Supreme Court affirmed the judgment in its entirety, holding (1) there was sufficient evidence both to find that Defendant was a "major participant" in the victim's murder and to support two of the statutory aggravators; (2) the trial court did not abuse its discretion in declining to instruct the jury as proposed by Defendant; and (3) the record supported the other aggravating factors not relating to the life without parole sentence. View "Owen v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of life imprisonment without the possibility of parole (LWOP) in connection with his conviction for the murder and burglary of his ex-girlfriend, holding that Defendant's LWOP sentence was not inappropriate.On appeal, Defendant argued that the jury failed to meet all statutory prerequisites for an LWOP sentence by failing to determine that the aggravating circumstances outweighed the mitigating circumstances and that his sentence was inappropriate in light of the mental illness he was suffering when he committed the crimes. The Supreme Court affirmed, holding (1) the jury's LWOP recommendation reflected its determination that the aggravating circumstances outweighed the mitigating circumstances; and (2) the LWOP sentence was not inappropriate. View "Oberhansley v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal of his sentence, holding that Appellant's written plea agreement with the State unambiguously waived his right to appeal his sentence.Appellant pled guilty to four theft-related offenses in exchange for a more lenient sentence. Both Appellant and his attorney signed a three-page plea agreement with the State in which Appellant waived his right to appeal his sentence. Appellant sought to appeal his sentence despite his plea agreement. The Supreme Court dismissed the appeal, holding (1) Appellant waived his right to appeal his sentence; and (2) if Appellant's guilty plea was not knowing and voluntary because the trial judge's misstatements misled him as to which rights he was waiving, Appellant's remedy was to vacate his conviction through post-conviction relief proceedings. View "Davis v. State" on Justia Law

The Supreme Court affirmed the decision of the juvenile court denying Appellant's request for relief under Trial Rule 60(B)(6), holding that the new jurisdictional rule announced in K.C.G. v. State, 156 N.E.3d 1281 (Ind. 2020), does not apply retroactively in a collateral attack to render a final delinquency adjudication void.Prior to 2021, the Juvenile Code defined a "delinquent act" only as an act committed by a child "that would be an offense if committed by an adult." In K.C.G., the Supreme Court concluded that Ind. Code 35-47-10-5 (the dangerous-possession-of-a-firearm statute) expressly applied only to child and thus could never be committed by an adult. At issue in this case was whether the jurisdictional rule announced in K.C.G. applies retroactively to collaterally attack a final delinquency adjudication as void. The Supreme Court affirmed the judgment of the juvenile court in this case denying the relief sought by Appellant under Trial Rule 60(B)(6), holding that this Court's K.C.G. decision does not apply retroactively. View "M.H. v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting a motion to compel arbitration brought by Defendant Star Financial Group, Inc. in this class-action complaint alleging that Defendant collected improper overdraft fees, holding that Plaintiffs' account agreement did not allow Defendant to add an addendum to the terms and conditions of the account agreement.When Plaintiffs opened their checking account they assented to an account agreement detailing the terms and conditions of their relationship with Defendant. Before Plaintiffs brought this suit Defendant added an arbitration and no-class-action addendum to the terms and conditions of Plaintiffs' account agreement. When Plaintiffs filed this lawsuit Defendants cited the addendum and filed a motion to compel arbitration. The trial court granted the motion. The Supreme Court reversed, holding that Plaintiffs were not bound by the arbitration addendum to their account agreement because the account agreement's change-of-terms provision did not allow Plaintiff to add the addendum. View "Decker v. Star Financial Group Inc." on Justia Law

The Supreme Court vacated the order of the trial court concluding that a constitutional taking of Landowners' property occurred from government-induced flooding, holding that whether the flooding's interference was substantial enough to create a taking was a question left unresolved by the trial court's findings.In 2009, the Town of Linden and Montgomery County approved a drainage-improvement plan that called for a reconstruction project that included a drainage easement on Landowners' property. After completion of the project, portions of Landowners' property flooded after any heavy rainfall, encumbering their farming enterprise. Landowners sued the Town and County for inverse condemnation. After remand, the trial court concluded that the project amounted to a taking. The Supreme Court vacated the trial court's order, holding (1) the trial court properly analyzed the government-induced flooding as a permanent physical invasion; and (2) the statutory right of entry set forth in Ind. Code Ann. 36-9-27-33 does not exempt a county from liability for a takings claim. View "Town of Linden v. Birge" on Justia Law