Justia Indiana Supreme Court Opinion Summaries

Jefferson County awarded the first phase of its courthouse remodeling plan to a contractor. Two subcontractors aided in the repairs. While the repairs were underway, a fire severely damaged the courthouse. Jefferson County’s contract with the contractor incorporated an American Institute of Architects (AIA) standard form. The AIA contract waives subrogation rights for damages caused by fire “to the extent covered by property insurance.” Jefferson County filed a subrogation claim against the Contractors to recover damages caused to its property unrelated to repairs. Defendants moved for summary judgment, arguing that Jefferson County had waived its claim under the AIA waiver because its insurance policy covered all the damages. The County responded that the subrogation waiver applied only to construction-related damages. The trial court granted summary judgment for Defendants, concluding that Jefferson County had waived subrogation rights for all claims. The Supreme Court affirmed, holding (1) the plain language of the AIA contract restricts the scope of the waiver based on the source and extent of property insurance coverage, not the nature of the damages; and (2) the County agreed to waive its rights to bring this subrogation claim by relying on its existing “all-risk” property insurance policy that covered the work and all other losses suffered in the fire. View "Bd. of Comm’rs v. Teton Corp." on Justia Law

YTC Dream Homes, Inc. and other franchisees (collectively, YTC) filed in Lake Superior Court a contract-related action against franchisor DirectBuy, Inc. and related parties (collectively, DirectBuy). YTC filed a motion requesting pro hac vice admission of five out-of-state attorneys to represent YTC in the case. The trial court initially granted YTC’s motion but, upon the objection of DirectBuy, vacated its original order and issued an order denying YTC’s motion, holding that YTC did not overcome the presumption under Lake County Local Rule 5(C) that an attorney not licensed in Indiana is not permitted to practice before it. The Supreme Court reversed, holding that Local Rule 5(C) does not create a presumption against pro hac vice admissions. Remanded to the trial court with instructions to determine, within the discretion granted by the Indiana Admission and Discipline Rule 3(2), whether good cause exists for the admission of the attorneys. View "YTC Dream Homes, Inc. v. DirectBuy, Inc." on Justia Law

After a jury trial, Defendant was convicted of molesting his three young granddaughters. Defendant appealed, arguing that he was entitled to separate trials on the allegations of each individual victim. The Court of Appeals reversed and remanded for new and separate trials, concluding that Defendant was entitled to severance under Ind. Code 35-34-1-11(a). The Supreme Court granted the State’s petition to transfer, thereby vacating the opinion below, and affirmed, holding that Defendant’s abuse of girls in this care was sufficiently connected, and therefore, Defendant was not entitled to new and separate trials. Remanded for the purpose of resentencing on one count. View "Pierce v. State" on Justia Law

Seventeen-year-old J.K. and her mother lived with J.D.’s maternal grandmother. In 2013, the Marion County Department of Child Services (DCS) initiated CHINS proceedings over J.K. Father, whose divorce with Mother was pending, denied that J.K. was in need of services. After two hearings, during which the trial court made several derogatory remarks about the parties and the nature of their dispute, the court pressured Father to waive his right to a fact-finding hearing and to instead admit that his daughter was a child in need of services (CHINS). The Supreme Court reversed the CHINS adjudication, holding that the cumulative effect of the trial court’s comments and demeanor had a direct impact on Father accepting the court’s suggestion to “waive fact-finding,” and such coercion is fundamental error. View "M.K. v. Marion County Dep’t of Child Servs. & Child Advocates, Inc." on Justia Law

In 2007, when the parties’ child was just over two years old, Father and Mother’s marriage was dissolved. In 2013, Father filed to modify his support obligation given an increased number of overnights Father was having with the child and a decrease in childcare costs. Under the Indiana Child Support Guidelines, the applicable parenting time credit decreased Father’s support obligation from $135 per week to $59 per week. Mother sought a deviation from the recommended amount, arguing that she could not properly support the child with such a minimal contribution from Father. The trial court agreed with Mother and deviated upward from the recommended support but still reduced Father’s previous support obligation to $105 per week. The Supreme Court affirmed the trial court’s child support modification order, holding that the trial court did not commit clear error when it deviated from the Guidelines by not granting Father the full parenting time credit and permitted Mother to claim the child each year for the federal and state dependency tax exemption. View "Bogner v. Bogner" on Justia Law

DePuy Orthopaedics, an Indiana corporation with its principal place of business in Indiana, sold a prosthetic hip implant that Plaintiffs, nineteen individuals, had implanted during hip replacement surgeries in Virginia and Mississippi. After DePuy issued a voluntary global recall of the prosthetic hip implant Plaintiffs filed suit in Marion Superior Court, alleging injuries related to the hip replacement equipment. DePuy moved to transfer venue to Virginia and Missisippi on the grounds of forum non conveniens pursuant to Indiana Trial Rule 4.4(C). The trial court denied the motion. The Supreme Court affirmed, holding that there was sufficient evidence for the trial court to have reasonably concluded that Indiana was the appropriate forum for this litigation. View "DePuy Orthopaedics, Inc. v. Brown" on Justia Law

After a jury trial, Defendant was convicted of murder and robbery. Defendant was sentenced to life imprisonment without parole for the murder conviction. The Supreme Court affirmed, holding (1) the evidence was sufficient for a reasonable jury to conclude that Defendant committed the offense of robbery; (2) the evidence was sufficient to prove the charged statutory predicate for the sentence of life imprisonment without parole; (3) the trial court did not err by admitting evidence regarding Defendant’s attempt to commit suicide two days after police questioned him about the murder; (4) the trial court did not err in allowing testimony over objection regarding Defendant’s appearance the day after the murder; and (5) Defendant’s sentence of life imprisonment without parole was appropriate. View "Stephenson v. State" on Justia Law

Appellant, a large managed health care organization, settled certain federal multi-district litigation without admitting liability. At all times relevant to this litigation, Appellant was was its own primary and excess insurer for errors and omissions liability, with a certificate of reinsurance on its primary policy issued by one reinsurer and numerous certificates of reinsurance on its excess policies issued by additional reinsurers. Appellant sought indemnification from its reinsurers. Some of those reinsurers denied coverage, whereupon Appellant filed the instant suit claiming professional liability coverage under the policies. The trial court granted summary judgment in favor of the reinsurers. The Supreme Court reversed and in large part granted summary judgment for Appellant, holding that Appellant was largely entitled to coverage for defense costs under its policies with the reinsurers. View "WellPoint, Inc. v. Nat’l Union Fire Ins. Co." on Justia Law

A law firm (Plaintiff) filed a quantum merit claim for part of the contingent fees earned in cases that were first handled by the law firm’s attorneys, including Defendant, and later by Defendant and his law firm after he left Plaintiff’s law firm. The trial court denied quantum merit relief, finding that Defendant was not unjustly enriched. The court of appeals affirmed. The Supreme Court granted transfer and (1) reversed and remanded with instructions to determine, in accordance with Galanis v. Lyons & Truitt, what proportional contributions toward the results in the cases at issue were made by attorneys working for Plaintiff, and to enter a corresponding judgment in Plaintiff’s favor; and (2) summarily affirmed the portion of the court of appeals’ opinion addressing whether Plaintiff should have sued its former clients to recover attorney fees from them. View "Cohen & Malad, LLP v. Daly" on Justia Law

In 2000, Appellant was diagnosed with paranoid schizophrenia. In 2004, while unprovoked, Appellant fired a shotgun several times at multiple vehicles, including a police cruiser. The jury returned verdicts of guilty but mentally ill on four counts of Class A felony attempted murder. Appellant was sentenced to an aggregate sentence of 120 years. The court of appeals reversed Appellant’s convictions, concluding that (1) jury clearly erred in rejecting Appellant’s insanity defense, and (2) the admission of evidence regarding Appellant’s post-arrest silence and request for counsel, and the prosecution’s closing arguments relying on those instances as evidence of sanity, violated Appellant’s constitutional due process rights. The Supreme Court granted the State’s petition to transfer, thereby vacating the Court of Appeals opinion, and affirmed the the jury's verdict finding Appellant guilty but mentally ill, holding (1) there was sufficient evidence for a jury to draw a reasonable inference that Defendant was able to appreciate the wrongfulness of his conduct at the time of the offense; (2) there was no due process violation; and (3) Appellant’s sentence was appropriate. View "Myers v. State" on Justia Law