Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder. Defendant appealed, arguing, among other things, that the trial court erred in refusing his proposed final jury instruction regarding the presumption of innocence. The Court of Appeals affirmed. The Supreme Court granted transfer in order to state precisely what jury instructions a criminal defendant is entitled to receive regarding the presumption of innocence and held (1) it is the right of every criminal defendant to receive the following jury instruction upon request: “The presumption of innocence continues in favor of the defendant throughout the trial. You should fit the evidence to the presumption that the defendant is innocent if you can reasonably do so[ ]”; and (2) the trial court’s failure in this case to use this precise language was not error because the jury instructions adequately encompassed these principles. View "McCowan v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony murder and murder. Defendant was sentenced to sixty-five years for the felony murder and life without parole for the murder. Defendant appealed, asserting that there was insufficient evidence for his convictions and that the incredible dubiosity rule should be applied because no reasonable jury could have found him guilty beyond a reasonable doubt given the inconsistent testimony among three of the State’s primary witnesses. The Supreme Court affirmed Defendant’s convictions and sentence, holding that the evidence was sufficient for a reasonable jury to find Defendant guilty beyond a reasonable doubt for both murders. View "Moore v. State" on Justia Law

The State filed a complaint against Defendant seeking forfeiture of her 1996 Buick Century automobile under the provisions of the Civil Forfeiture Statute, which provides in relevant part that a vehicle may be seized if it is used or is intended for use by the person in possession of it to facilitate the transportation of stolen property. On cross-motions for summary judgment the trial court deemed the vehicle forfeited and awarded the vehicle to the Indianapolis Metropolitan Police Department. The Supreme Court reversed, holding that the State was not entitled to forfeiture of the vehicle because it failed to demonstrate that Defendant was “in possession” of the vehicle as contemplated by the Civil Forfeiture Statute. View "Sargent v. State" on Justia Law

In 2010, due to a large budget deficit, Franklin Township Community School Corporation voted to discontinue transportation services for the majority of students attending its public schools. Parents of students who attend public schools in Franklin School Corporation brought a class action suit seeking a declaratory judgment that discontinuing transportation is prohibited under the Education Clause of the Indiana Constitution. The trial court granted summary judgment in favor of Franklin School Corporation. The Supreme Court affirmed, holding that the Indiana Constitution does not mandate school corporations to provide transportation to and from school, and therefore, Franklin School Corporation did not violate a constitutional mandate. View "Hoagland v. Franklin Township Cmty. Sch. Corp." on Justia Law

After a bench trial, Defendant was found guilty of criminal trespass as a class A misdemeanor in violation of Ind. Code 35-43-2-2(a)(4) and was sentenced to 365 days in jail. Defendant appealed, challenging the sufficiency of the evidence to support his conviction. The Court of Appeals affirmed. The Supreme Court granted transfer, thereby vacating the Court of Appeals opinion, and reversed the trial court’s judgment, holding that the evidence in this case was insufficient to sustain Defendant’s conviction for Class A misdemeanor criminal trespass. View "Willis v. State" on Justia Law

Debtor filed for Chapter 7 bankruptcy protection and listed an insurance policy with Northwestern Mutual as an asset on his bankruptcy schedules. Debtor claimed the policy’s entire cash surrender value as exempt property because his son (Son) was the beneficiary. The bankruptcy Trustee objected because Son was an adult and not “dependent upon” Debtor within the meaning of Ind. Code 27-1-12-14(e). That statute exempts life insurance policies from debtors’ bankruptcy estates when the named beneficiary is the “spouse, children, or any relative dependent upon” the debtor. Because bankruptcy courts in the Northern and Southern Districts of Indiana had issued conflicting opinions about the proper interpretation of the statute, the Bankruptcy Court for the Northern District of Indiana certified to the Supreme Court the question of whether, under section 27-1-12-14(e), the phrase “dependent upon such person” modifies only “any relative” or modifies “spouse,” “children,” and “any relative.” The Court concluded that the phrase “dependent upon such person” does not modify “spouse” or “children,” but only “any relative” named as beneficiary of a life-insurance policy. View "In re Howell" on Justia Law

After a civil commitment hearing, the trial judge declared that, by clear and convincing evidence, T.K. was both dangerous and gravely disabled. The court then ordered T.K. to be involuntarily committed. The court of appeals affirmed. The Supreme Court granted transfer and reversed, holding that the evidence presented at the civil commitment hearing was insufficient to establish by clear and convincing evidence that T.K. was either dangerous or gravely disabled, and therefore, the civil commitment of T.K. was improper. View "In re Civil Commitment of T.K." on Justia Law

When Mother and Father’s marriage was dissolved in 1994, the trial court awarded Mother primary care and custody of the parties’ daughter (Daughter) and ordered Father to pay child support. In 2011, after Daughter enrolled at Ball State University (BSU), Mother petitioned to modify child support, requesting that Father pay Daughter’s postsecondary educational expenses. Daughter withdrew from BSU in 2012 and attempted to enroll at Indian University Northwest. BSU, however, would not release Daughter’s official transcript because of her outstanding tuition bill. Mother requested to join BSU as a supplemental defendant. The trial court granted the request and ordered BSU to release the transcript. The Supreme Court reversed, holding (1) the trial court’s order was appealable as of right under Indiana Appellate Rule 14(A)(3); and (2) the trial court abused its discretion in granting Mother’s motion for joinder, as Mother failed to carry her burden in demonstrating that BSU was a necessary party under Trial Rule 19. View "Ball State University v. Irons" on Justia Law

Indiana Restorative Dentistry, P.C. (“IRD”) insured its dentist’s office under a policy issued by ProAssurance Indemnity Company, Inc. (“ProAssurance”) and procured through the Laven Insurance Agency, Inc. (“Laven”). After a fire destroyed the entire IRD office, IRD discovered that the contents coverage of its insurance policy was inadequate to cover its loss. IRD sued ProAssurance and Laven in tort and contract. The trial court granted partial summary judgment for ProAssurance, concluding that Laven had no duty to advise based on a special relationship, that Laven had no contractual duty to procure insurance that would have fully covered the fire losses, and that ProAssurance was not vicariously liable for the alleged acts or omissions of Laven. The Supreme Court affirmed in part and reversed in part, holding (1) genuine issues of material fact remained regarding the existence of a special relationship between IRD and Laven and, consequently, a duty to advise; and (2) Laven had no duty to procure full coverage because there was no evidence showing a “meeting of the minds” on an implied contract requiring Laven to procure a policy that would cover all losses to office contents. View "Ind. Restorative Dentistry, P.C. v. Laven Ins. Agency, Inc." on Justia Law

Defendant was found guilty of patronizing a prostitute. Defendant appealed, arguing that he had raised the entrapment defense by showing police inducement and that the State failed to offer any evidence of Defendant’s predisposition to commit the offense. The Court of Appeals agreed with Defendant and reversed. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and affirmed the trial court, holding (1) Defendant’s entrapment defense failed because a reasonable trier of fact could have found the State proved beyond a reasonable doubt that the police did not induce Defendant; and (2) therefore, the Court did not need to address the question of Defendant’s predisposition to commit the crime. View "Griesemer v. State" on Justia Law