Justia Indiana Supreme Court Opinion Summaries

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

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

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