Justia Indiana Supreme Court Opinion Summaries

When Barbara and Michael Pohl divorced, they entered into a custody, support, and property settlement agreement that was incorporated into their dissolution decree. Because the original agreement did not provide for spousal maintenance, the parties filed an addendum calling for Barbara to pay Michael monthly maintenance. Barbara later filed a petition to modify her maintenance obligation. The trial court denied Barbara’s request, concluding that the agreement was not intended to be modifiable. The Supreme Court reversed, holding (1) principles of contract finality preclude modification of a maintenance award unless the agreement is modifiable by its own terms; and (2) the parties’ agreement in this case was modifiable because they expressly made the agreed maintenance amount subject to “further order of the court,” echoing the language of the incapacity maintenance statute. Remanded. View "Pohl v. Pohl" on Justia Law

Hanover College, the beneficiary of two trusts, filed petitions requesting that the trusts be terminated. Old National Bancorp, d/b/a Old National Trust Company, as trustee for both trusts, filed responses to Hanover’s petitions. The trial court granted the petitions and ordered the two trusts dissolved and the trust assets distributed to Hanover. Rather than seek a stay of the trial court’s dissolution orders, Old National appealed. The court of appeals dismissed Old National’s appeal, concluding (1) Old National lacked standing in its representative capacity because it failed to obtain a stay of the trial court’s termination orders and was therefore no longer the trustee of the trusts; and (2) because Old National did not intervene in its individual capacity at trial it could not be an aggrieved party on appeal. The Supreme Court likewise dismissed Old National’s appeal, holding that the trustee lacked standing to pursue the appeal in its representative capacity and did not appeal in its individual capacity. View "Old Nat’l Bancorp v. Hanover College" on Justia Law

TP Orthodontics’ (TPO) board of directors formed a special litigation committee (the SLC) to investigate derivative claims filed by sibling minority shareholders. Following a lengthy investigation, the SLC produced a report. Based on recommendations contained in the report TPO filed a motion to dismiss certain derivative claims, attaching a redacted version of the report in support of its motion. The SLC report had been heavily redacted to protect attorney-client communications and attorney work product. The sibling shareholders filed a motion to compel production of the full report, seeking to access the full report in order to contest the SLC’s conclusions. The trial court granted the motion. The Supreme Court remanded the case to the trial court with directions for TPO to specifically identify privileged attorney-client communications and attorney work product contained within the report and the trial court to review in camera the revised redacted SLC report and privilege designations to determine whether the designated material was in fact privileged. View "TP Orthodontics, Inc. v. Kesling" on Justia Law

Appellant was charged with several felony offenses and two misdemeanor offenses arising from a foiled drug sale. Appellant was found guilty as charged. After Appellant was sentenced, a post-conviction court scheduled the matter for a resentencing hearing. Following resentencing, the trial court sentenced Appellant to an aggregate term of thirty-eight years. The Supreme Court vacated Appellant’s conviction and five-year sentence imposed under the handgun enhancement charge, holding that the trial court erred by entering convictions and sentences for both carrying a handgun without a permit and use of a firearm in controlled substance offense as an enhancement based on possession of the same handgun. Remanded. View "Cross v. State" on Justia Law

The Indiana Department of Environmental Management (IDEM), Indiana’s environmental agency, revised its interpretation of the regulatory term “chemical process plants.” After IDEM issued operating permits to two companies for ethanol and ethanol production facilities, NRDC sought administrative review of both permits based on the interpretation of the term “chemical process plants.” The Indiana Office of Environmental Adjudication (OEA) ordered the permits remanded to IDEM. The companies and others sought judicial review of the OEA order. The trial court reversed the OEA. The Supreme Court affirmed, holding (1) IDEM was not required to formally amend Indiana’s State Implementation Plan to effectuate its change in how it interprets the regulatory phrase “chemical process plant”; and (2) IDEM’s new interpretation was reasonable and supported the issuance of the permits in this case. View "Nat. Res. Defense Council v. Poet Biorefining- North Manchester, LLC" on Justia Law

An Estate filed an adult wrongful death medical malpractice action against a nursing home. The Estate settled its claim against the nursing home for $250,000, the maximum liability of the health care provider under Indiana’s Medical Malpractice Act (MMA). Thereafter, the Estate filed a petition to determine the amount of excess damages it was due from the Indiana Patient’s Compensation Fund. The Estate and the Fund agreed on the amount of damages but left the attorney fee component of damages for determination by the trial court. The trial court ordered the Fund to pay the Estate $50,440 for attorney fees. The Fund appealed, arguing that, in an action to recover for the wrongful death of an adult, the fifteen percent limit on attorney fees imposed by the MMA (the "fee cap provision") should be applied such that the Fund should not be required to pay a claimant an amount for attorney fees exceeding fifteen percent. The Supreme Court affirmed, holding that the fee cap provision applies to cap the fees that the plaintiff’s lawyer may charge as to the award the client receives from the Fund but does not lessen the Fund’s liability to a claimant. View "Ind. Patient's Comp. Fund v. Holcomb" on Justia Law

At issue in this case was whether Indiana’s tax statutes allow Caterpillar, Inc. to increase its Indiana net operating losses (NOLs) by deducting foreign source dividend income. Caterpillar commenced an original tax appeal in the Indiana Tax Court challenging the Indiana Department of State Revenue’s longstanding application of the Indiana tax statutes. The Tax Court entered summary judgment for Caterpillar, concluding that the Indiana NOL statute does not reference or incorporate the foreign source dividend deduction. The Supreme Court reversed, holding that Caterpillar may not deduct foreign source dividends when calculating Indiana NOLs, and Caterpillar did not meet its burden to show that disallowing the deduction discriminates against foreign commerce under the Foreign Commerce Clause. View "Ind. Dep’t of State Revenue v. Caterpillar, Inc." on Justia Law

Law enforcement officers arrested Defendant on two counts of theft and seized his clothing, including his shoes, in accordance with their standard booking protocols. After police found what appeared to be blood under the laces of Defendant’s left shoe they subjected the shoe to laboratory testing. The testing revealed the presence of a murder victim’s DNA in that blood. Defendant was charged with murder and theft. Defendant moved to suppress the DNA evidence found on his shoe, arguing that the police should have obtained a separate warrant before subjecting the shoe to testing. The trial court denied the motion, and Defendant was subsequently convicted on all charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that police need not obtain a warrant before subjecting lawfully seized evidence to laboratory testing even if that evidence is unrelated to the crime for which the defendant is in custody. View "Guilmette v. State" on Justia Law

Under the terms of a plea agreement Defendant pleaded guilty to one count of class A felony criminal deviate conduct and class B felony robbery. The trial court sentenced Defendant to a total executed term of forty years. Defendant appealed the trial court’s imposition of his sentence, concluding that the trial court improperly found as an aggravating factor the “nature and circumstances” of the crime in that “the circumstances articulated by the trial court were essentially elements of the crime.” The Supreme Court affirmed, holding that the trial court did not abuse its discretion in imposing Defendant’s sentence, as the nature and circumstances of the crime were appropriate reasons justifying a sentence greater than the advisory term. View "Gomillia v. State" on Justia Law

Defendant was convicted for class A felony conspiracy to commit robbery resulting in serious bodily injury. Defendant appealed, arguing (1) there was insufficient evidence to support his conviction because the State failed to establish actual serious bodily injury to his alleged victim; and (2) the trial court erred by permitting the State to substantively amend the charging information on the second day of trial. The Supreme Court affirmed, holding (1) the State’s amendment was one of form and not of substance, and the trial court did not err in permitting the change; and (2) the State permitted sufficient evidence at trial to support Defendant’s conviction. View "Erkins v. State" on Justia Law