Justia Indiana Supreme Court Opinion Summaries
Schmidt v. Indiana Insurance Co.
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 The insurance company denied coverage and rescinded the policy because it contained material misrepresentations and false statements.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
Posted in:
Insurance Law
Gertiser v. Stokes
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
Posted in:
Family Law
Hernandez v. State
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
Posted in:
Criminal Law
Comm’r of Ind. Bureau of Motor Vehicles v. Vawter
Plaintiffs, as a certified class, challenged the constitutionality of the program utilized by the Indiana Bureau of Motor Vehicles (BMV) in the processing of applications for personalized license plates (PLPs), arguing that the decision making process used in denying or revoking PLPs violates the First Amendment and the Due Process Clause. The trial court granted summary judgment in favor of the class, concluding that the statute that authorizes the BMV to refuse to issue PLPs and its related policies are vague, overbroad, and lacking in content-neutrality and that the Bureau violates due process safeguards by providing insufficient reasons for a denial or revocation of a PLP. The Supreme Court reversed, holding (1) PLPS are government speech; and (2) therefore, the statute and policies at issue in this case are constitutional. View "Comm’r of Ind. Bureau of Motor Vehicles v. Vawter" on Justia Law
Posted in:
Civil Rights, Constitutional Law
Lee v. State
The State prosecuted three co-defendants on identical charges in the same trial. The Supreme Court reversed the convictions of two of those three co-defendants and remanded to the trial court with instructions to enter judgments of acquittal. The case involving the third co-defendant, Latoya Lee, was indistinguishable from the cases of her two co-defendants with the exception that she belatedly filed her petition to transfer. The Supreme Court granted Latoya’s petition to transfer and reversed her conviction, holding that there was no reason to treat her differently that her co-defendants, who now stand acquitted. Remanded with instructions to enter a judgment of acquittal. View "Lee v. State" on Justia Law
Posted in:
Criminal Law
Williams v. State
After a jury trial, Defendant was found guilty of two felony counts of dealing in cocaine. The Court of Appeals affirmed, concluding that a detective’s opinion testimony on witnessing a drug transaction led only to an inference of guilt and was not an opinion of guilt itself in violation of Ind. R. Evid. 704(b). The Supreme Court granted transfer, holding (1) the trial court erred in admitting the detective’s statement, as the statement was an opinion of Defendant’s guilt that violated Rule 704(b); (2) the admission of the guilt opinion testimony, however, was harmless error; and (3) on all other issues, the Court of Appeals is summarily affirmed. View "Williams v. State" on Justia Law
Posted in:
Criminal Law
Masters v. Masters
Husband and Wife signed an agreement to arbitrate the issues in their divorce under the Family Law Arbitration Act (FLAA). The family law arbitrator entered conclusions of law providing for legal and physical custody of the parties’ child to be granted to Wife, Husband to pay certain child support obligation, the division of the marital property, Husband to pay certain spousal maintenance costs, and Husband to pay $95,000 of Wife’s attorney’s fees. The trial court entered judgment in accordance with the arbitrator’s decision. Husband appealed the arbitrator’s attorney fee award. Wife cross-appealed other issues. The Supreme Court affirmed, holding (1) in the appellate consideration of an FLAA award, the proper standard of review is the same standard of appellate review that applies to the review of trial court decisions in marriage dissolution cases; and (2) in this case, the family law arbitrator’s award satisfies that standard, and Husband failed to establish that the award of attorney’s fees is not supported by the arbitrator’s findings. View "Masters v. Masters" on Justia Law
Posted in:
Arbitration & Mediation, Family Law
Tiplick v. State
Defendant was charged with possessing, selling and dealing in the chemical compound designated XLR11 and dealing and conspiracy to commit dealing in look-alike substances. Defendant filed a motion to dismiss the charges, claiming that the information failed to reference the Indiana Board of Pharmacy’s Emergency Rule 12-493(E), which criminalized XLR11; the applicable statutory schemes were void for vagueness; and the General Assembly could not delegate to the Pharmacy Board the power to criminalize XLR11. The trial court denied Defendant’s motion. The Supreme Court (1) affirmed the trial court’s denial of Defendant’s motion to dismiss the charges against him under the applicable statutes, holding that there was no constitutional or statutory infirmity to any of the charges; but (2) dismissed the XLR11-related charges, holding that the charging information was inadequate with respect to those charges. Remanded. View "Tiplick v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Helsley v. State
After a jury trial, Defendant was found guilty of two counts of murder. The trial court sentenced Defendant to life imprisonment without parole. Defendant sought post-conviction relief and subsequently received a new sentencing hearing. At the conclusion of the hearing, the jury recommended a sentence of life imprisonment without parole, and the trial court sentenced Defendant accordingly. Defendant appealed his sentence, seeking a reduction to a term of years. The Supreme Court affirmed, holding (1) the nature of the offense and the character of Defendant do not present a sufficiently compelling basis to override the decision of the jury and the trial court; and (2) Defendant’s claim that the jury’s weighing of aggravating and mitigating factors was an abuse of discretion was nonjusticiable. View "Helsley v. State" on Justia Law
Posted in:
Criminal Law
Gibson v. State
After a jury trial, Defendant was found guilty of murder. The trial judge sentenced Defendant to death for the murder. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant’s request for a fourth continuance; (2) did not err in refusing to dismiss an entire venire panel or declare a mistrial based on some potential jurors’ exposure to Defendant’s other murder charges; (3) did not abuse its discretion in denying Defendant’s request to ask a case-specific question during voir dire; (4) did not abuse its discretion in denying Defendant’s for-cause juror challenges; and (5) did not abuse its discretion in declining to instruct the jury on voluntary manslaughter. Further, Defendant’s sentence of death was not inappropriate. View "Gibson v. State" on Justia Law
Posted in:
Criminal Law