Justia Indiana Supreme Court Opinion Summaries

Plaintiff, a church, filed a complaint for declaratory judgment seeking to determine the boundary line between it and Defendants, homeowners, to determine ownership of its real estate, to allow it to build a fence along the boundary line, and seeking an injunction to prevent Defendants from further trespassing. The homeowners counterclaimed, arguing that they had acquired title to the disputed real estate by adverse possession as well as prescriptive easement. The trial court granted summary judgment in favor of Defendants on both the adverse possession and prescriptive easement claims. The Supreme Court affirmed the trial court on both claims, holding that Defendants were entitled to summary judgment on their claims of adverse possession and prescriptive easement. View "Celebration Worship Ctr., Inc. v. Tucker" on Justia Law

Defendant pleaded guilty to multiple counts each of class C felony neglect of a dependent and class C felony criminal confinement. The plea agreement left sentencing to the discretion of the trial court but capped Defendant’s sentence at ten years pursuant to Ind. Code 35-50-1-2(c). This section, however, did not actually apply to Defendant. The trial court accepted the plea agreement and sentenced Defendant to ten years pursuant to the perceived statutory cap. Defendant appealed, challenging the trial court’s imposition of the aggregate sentence. The court of appeals reversed Defendant’s sentence, determining, sua sponte, that the erroneous application of section 35-50-1-2(c) rendered the plea agreement void as a matter of law. The Supreme Court granted transfer, thus vacating the decision below, and affirmed the trial court’s acceptance of Defendant’s plea agreement and its imposition of a ten-year sentence, holding that Defendant’s plea agreement was valid and enforceable despite the mistaken application of section 35-50-1-2(c). View "Russell v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary, a class C felony. The Court of Appeals reversed the conviction, finding that the conviction was obtained through the State’s knowing use of perjured testimony. The Supreme Court granted transfer, thus vacating the opinion of the Court of Appeals, and affirmed the conviction, holding (1) Defendant’s due process rights were not implicated by the inconsistent testimony, as the State notified opposing counsel and the court of the conflicting testimony and proactively drew attention to the discrepancies in the testimony throughout the trial, thus permitting the jury to fully function as an informed fact finder; and (2) the incredible dubiosity rule was not applicable to this case. View "Smith v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder and arson. The trial court sentenced Defendant to life imprisonment without the possibility of parole (LWOP). The Supreme Court affirmed, holding (1) the jury’s decision not to find Defendant insane or guilty but mentally ill was not contrary to law; (2) the trial court did not abuse its discretion by admitting testimony about Defendant’s evasiveness during police questioning because it was admissible as lay opinion testimony; and (3) Defendant’s LWOP sentence was not inappropriate under Appellate Rule 7(B) based on the nature of the offense and Defendant’s character. View "Satterfield v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, felony murder, criminal deviate conduct, and resisting law enforcement. The trial judge sentenced Defendant to life imprisonment without the possibility of parole and an additional term of three years for resisting law enforcement. The Supreme Court affirmed the convictions but reversed the sentencing determination, holding (1) the evidence was sufficient to support the conviction for criminal deviate conduct; (2) the trial court’s failure to give a reasonable theory of innocence instruction was not fundamental error; (3) the trial court erred in admitting testimony regarding Defendant’s prior conduct while consuming alcohol, but the error was harmless; and (4) the sentencing order did not contain a personal conclusion by the judge that life without parole was an appropriate punishment, in violation of Harrison v. State and Pittman v. State. Remanded for a revised sentencing order. View "Lewis v. State" on Justia Law

After I.B. and W.B. were removed from their parents, both their paternal and maternal grandmothers petitioned to adopt them. The trial court found that it was in the best interests of the children for the maternal grandmother and her fiancé to adopt them the maternal grandmother had a prior felony conviction that statutorily disqualified her from adopting. The court of appeals affirmed, concluding that the statutory disqualification was unconstitutional as applied because it amounted to an irreubttable presumption in violation of due process. The Supreme court granted transfer and reversed, holding that the statute is constitutional, despite its harsh consequences under the facts of this case. View "In re Adoption of I.B." on Justia Law

Defendant was living in the residence of an individual who was home home detention under Community Corrections supervision when community corrections officers went into the residence to conduct a warrantless search to ensure Sullivan’s compliance with the conditions of the program. The ensuing search uncovered illegal drugs in the common areas in the residence as well as drugs and drug paraphernalia in Defendant’s private bedroom. Defendant was charged with maintaining a common nuisance and other drug-related offenses. The trial court granted Defendant’s motion to suppress in part, concluding that the Community Corrections officers had consent to search the common areas of the residence but not Defendant’s private bedroom. The Supreme Court reversed, holding that all of the evidence seized from the compliance search was the result of an improper entry and search because the home detention participant had agreed to written conditions of his participation that consented only to searches upon probable cause, which was wholly lacking in this case. Remanded with instructions to grant the motion to suppress in its entirety. View "State v. Vanderkolk" on Justia Law

Jerry Earl sustained severe injuries in a motorcycle accident. Jerry had a policy with State Farm, which provided uninsured motorist coverage. Earl and his wife Kimberly (together, Plaintiffs) sued State Farm when State Farm refused to pay out the full amount under the policy. State Farm admitted liability, and the case proceeded to a jury on the question of damages. The jury returned a verdict of $250,000, the exact amount of the coverage limit. State Farm appealed, arguing that the trial court abused its discretion by allowing the coverage limit into evidence. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in admitting the coverage limit. View "State Farm Mut. Auto. Ins. Co. v. Earl" on Justia Law

Jason and Justina Kramer hired Catholic Charities to facilitate the adoption of E. After M.S. gave birth to E., the Kramers took E. home with them. The Kramers subsequently learned that R.M. had registered as the putative father of E. The Kramers nonetheless petitioned to adopt E., and R.M. contested the adoption. R.M. received full custody of E. after E. had been in the Kramers’ custody for eight months. The Kramers brought a negligence action against Catholic Charities, alleging that Catholic Charities should have checked the putative father registry prior to placing E. with them, or, alternatively, that Catholic Charities had a duty to disclose its failure to conduct a pre-placement check of the registry. The trial court granted summary judgment for Catholic Charities. The Supreme Court affirmed, holding (1) the applicable Indiana statute does not impose the requirement of a pre-placement registry check; and (2) the Kramers failed to demonstrate that Catholic Charities had any duties with respect to the putative father registry in excess of its statutory obligations. View "Kramer v. Catholic Charities of the Diocese of Fort Wayne-South Bend, Inc." on Justia Law

After a jury trial, Defendant was convicted of a Class C felony battery. Defendant appealed, arguing that he was denied a meaningful opportunity to present a complete defense because the trial court prevented him from presenting testimony of two witnesses that were critical to his claim of self-defense. At trial, Defendant asserted that the testimony was necessary for the purpose of impeaching the victim’s testimony that he had not been the aggressor. The Supreme Court affirmed, holding (1) under Ind. R. Evid. 613(b), extrinsic evidence of a prior inconsistent statement may be admitted before or after a witness is given the opportunity to explain or deny the alleged statement; and (2) in accordance with this interpretation, the trial court properly exercised its discretion in excluding Defendant’s proposed extrinsic evidence. View "Griffith v. State" on Justia Law