Justia Indiana Supreme Court Opinion Summaries

The operator of a wholesale greenhouse business hired a contractor to remove a large tree at its business. As a result of the work, the contractor received the wood from the removed tree, and the business paid the contractor $600. To complete the work, the contractor hired Appellant, a tree climber-cutter, to remove the trunk of the tree. Appellant was severely injured while working and rendered a paraplegic. The business brought this declaratory judgment action seeking to establish that it had no secondary liability because the value of the work by the contractor was less than $1,000. The trial court granted summary judgment for the business. The Supreme Court reversed, holding (1) the “value” attributable to the performance of work that triggers secondary liability under Ind. Code 22-3-2-14(b) includes both direct monetary payment as well as ancillary consideration received for the work; and (2) the business was not entitled to summary judgment because it failed to designate evidence establishing that the undisputed value of the ancillary consideration it received - the wood - plus the $600 monetary payment did not exceed $1,000. View "Young v. Hood’s Gardens, Inc." on Justia Law

After a jury trial, Defendant was found guilty of attempted murder. At Defendant’s trial and during final instructions, the trial court properly instructed the jury on the crime of attempted murder. Although Defendant was not charged as an accomplice to attempted murder, and his attempted murder charge was not explicitly premised on a theory of accomplice liability, the trial court also instructed the jury on accomplice liability. During closing arguments, the State argued both direct liability and accomplice liability theories for the attempted murder. The verdict form also did not distinguish between Defendant’s potential direct liability or accomplice liability for the attempted murder. The jury found Defendant guilty as charged. Defendant appealed, arguing that the trial court erred by not instructing the jury that it must find he had the specific intent to kill when he knowingly or intentionally aided, induced, or caused another person to attempt murder. The Supreme Court reversed the conviction, holding that the trial court committed fundamental error by giving an instruction permitting the jury to convict Defendant of attempted murder as an accomplice without the specific intent to kill. View "Rosales v. State" on Justia Law

Defendant was intoxicated when he crashed his vehicle into a service vehicle, killing the service truck driver. After a trial, Defendant was found guilty of operating a motor vehicle while intoxicated in a manner endangering a person and operating a motor vehicle while intoxicated, but the jury deadlocked on the most serious of Defendant’s charges. Defendant moved for judgment on the verdicts. The trial court denied Defendant’s motion to compel an entry of judgment on the verdicts and permitted the State to retry Defendant on all counts. After a second trial, the jury once again found Defendant guilty of the lesser offenses and also found Defendant guilty of the more serious offenses of causing death when operating a motor vehicle while intoxicated as class B and C felonies. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s first deadlock on the most serious of his charges, paired with its finding of guilt as to the lesser offenses, did not equate to an implied acquittal of those more serious offenses; and (2) the prohibition against double jeopardy was not violated when Defendant was retried on the greater offenses upon which the jury was deadlocked. View "Cleary v. State" on Justia Law

After a bench trial, Defendant was found guilty of criminal deviate conduct and criminal confinement, among other offenses. Defendant appealed, arguing, inter alia, that the trial court erred in limiting his cross-examination of a witness concerning the alleged victim’s credibility for truthfulness. The Court of Appeals concluded that the trial court erred in excluding testimony regarding the alleged victim’s truthfulness and vacated Defendant’s conviction for criminal confinement. The Supreme Court granted transfer and affirmed the trial court, holding that the trial court did not abuse its discretion by prohibiting evidence of specific instances of conduct regarding the alleged victim’s truthfulness. View "Jacobs v. State" on Justia Law

Mrs. Bridgewater, a Fishers Adolescent Catholic Enrichment Society, Inc. (FACES) member parent, filed a complaint with the Indiana Civil Rights Commission, alleging that FACES refused a reasonable accommodation for her allergic daughter by not serving her beef instead of chicken at a social event, therefore discriminating against her due to her disability. FACES subsequently expelled the Bridgewater family. Mrs. Bridgewater then filed a second complaint with the Commission, alleging that FACES unlawfully retaliated against her family for filing the disability discrimination claim. FACES filed a motion to dismiss on the basis that the Commission did not have subject-matter jurisdiction because FACES was a religious organization, not an educational one. The Commission denied the motion to dismiss and awarded judgment in favor of Mrs. Bridgewater on the retaliatory discrimination claim. The Supreme Court vacated the Commission’s final order, holding that the Commission lacked authority to take any action other than the dismissal of these claims because the incident giving rise to the claims was not related to education and was thus not within the Commission’s prerequisite statutory authority. Remanded to grant FACES’s motion to dismiss as to both claims. View "Fishers Adolescent Catholic Enrichment Soc’y, Inc. v. Bridgewater" on Justia Law

For most of the first year of her life, B.C.H. remained in the primary care, custody and control of her maternal grandparents (Grandparents), and Mother would visit her once a week. Mother later married Stepfather, who petitioned to adopt B.C.H. The petition was granted. Grandparents filed a motion to reopen B.C.H.’s adoption and to intervene, arguing that, under Indiana’s adoption statutes, they had “lawful custody” of B.C.H. when Stepfather’s adoption petition was granted, so they were entitled to legal notice of and the opportunity to consent to the adoption. The superior court denied Grandparents’ motion for relief from judgment, determining that Grandparents did not have legal custody of B.C.H. at the time Stepfather filed the adoption petition. The court of appeals affirmed. The Supreme Court vacated the decision of the superior court, holding that Grandparents had lawful custody of B.C.H., and therefore, Grandparents were entitled to formal legal notice of the pending adoption and an opportunity to give or withhold their consent to Stepfather’s adoption of B.C.H. Remanded. View "In re Adoption of B.C.H." on Justia Law

Defendant was convicted under Indiana’s public intoxication statute of being intoxicated in a public place and engaging in annoying conduct. Defendant appealed, arguing that the term “annoys” in the public intoxication statute is unconstitutionally vague and that there was insufficient evidence to sustain his conviction. The Supreme Court vacated Defendant’s conviction for misdemeanor public intoxication, holding (1) Indiana’s public intoxication statute is constitutional when a reasonableness standard is applied to the term “annoys”; and (2) in applying this reasonableness standard, there was insufficient evidence to sustain Defendant’s conviction for public intoxication. View "Morgan v. State" on Justia Law

After a jury trial, Defendant was convicted for being a serious violent felon in possession of a firearm. Defendant appealed, arguing, among other things, that the trial court erred by admitting a detective’s testimony that out-of-court witnesses identified Defendant as the suspect. The Supreme Court affirmed, holding (1) the testimony of the detective was inadmissible hearsay, and therefore, trial court abused its discretion by admitting the testimony, but the erroneous admission of the hearsay testimony was harmless; and (2) there was no material variance between the allegations against Defendant and the proof used to convict him. View "Blount v. State" on Justia Law

When Father and Mother divorced, they reached an agreement regarding child support that substantially deviated from what would be ordered by applying the Indiana Child Support Guidelines. Later, Mother petitioned to modify Father’s child support obligation. The trial court granted the motion and modified Father’s support requirements. Father appealed, arguing that agreed child support terms cannot be modified absent a substantial and continuing change in circumstances that renders those terms unreasonable. The Court of Appeals affirmed. The Supreme Court granted transfer, adopted the portion of the Court of Appeals’ opinion that addresses the available grounds for modification, and summarily affirmed the portion of the Court of Appeals’ opinion addressing the trial court’s calculation of Father’s support obligation. View "Rolley v. Rolley" on Justia Law

After a jury trial, Defendant was found guilty of Class A felony dealing in methamphetamine, among other charges, and received an aggregate sentence of forty years. Defendant appealed his sentence under Ind. App. R. 7(B), arguing that his sentence was inappropriate given the nature of the offense and his character. The court of appeals ultimately determined that the sentence was appropriate. The Supreme Court concluded that, given the nature of the offense and the character of the defendant, Defendants’ sentence was inappropriate. Remanded to the trial court to impose a sentence of thirty years for dealing in methamphetamine. View "Parks v. State" on Justia Law