Justia Indiana Supreme Court Opinion Summaries

One year after the Indiana Department of Education and the Indiana State Board of Education (collectively, “DOE”) approved Teaching Our Posterity Success, Inc. (“TOPS”) as a Supplemental Educational Services provider, the DOE removed TOPS from its list of approved providers. TOPS sought administrative review of that removal. In response, DOE sent TOPS a letter declaring that TOPS will remain removed from the provider list. TOPS filed a petition for judicial review but did not file an official agency record. The trial court dismissed TOPS’ petition on the grounds of its failure to file a timely and complete agency record. The Supreme Court affirmed, holding (1) a petitioner seeking judicial review of an agency action must file with the trial court the agency record as defined by the Administrative Orders and Procedures Act (AOPA); and (2) because TOPS did not file the agency record as anticipated by the AOPA, the trial court properly dismissed its petition for judicial review. View "Teaching Our Posterity Success, Inc. v. Ind. Dep’t of Educ." on Justia Law

Plaintiffs, an exclusive-agency union and several of its members and officers (collectively, the Union), filed a complaint against the Attorney General and the Commissioner of the Indiana Department of Labor (collectively, the State), seeking a declaratory judgment that certain provisions of the Indiana Right to Work Law were unconstitutional. The trial court granted relief on the Union’s claim that two provisions of the Indiana Work Law violated Article 1, Section 21 of the Indiana Constitution, which provides that “[no] person’s particular services shall be demanded, without just compensation.” The first challenged provision of the Indiana Work Law prohibits employers from requiring union membership or the payment of monies as a condition of employment, and the second provision makes the knowing or intentional violation of the first provision a Class A misdemeanor. The Supreme Court reversed, holding that the two provisions do not violate Section 21 because the challenged provisions do not constitute a demand by the State for particular services. View "Zoeller v. Sweeney" on Justia Law

Appellant was convicted of conspiracy to deal in cocaine as a class B felony and sentenced to an executed term of sixteen years. After an unsuccessful appeal, Appellant filed a pro se petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court denied relief. Still acting pro se, Appellant attempted to appeal the denial of his petition, but despite his “best efforts,” the appeal went awry. The court of appeals dismissed the appeal. The Supreme Court granted transfer, thereby vacating the court of appeals’ order. After full briefing on the merits, the Supreme Court affirmed the judgment of the post-conviction court, holding that the post-conviction court did not err in denying Appellant’s claim that counsel rendered ineffective assistance. View "Hollowell v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of attempted murder, burglary resulting in serious bodily injury, aggravated battery, and battery. Defendant later filed a petition for post-conviction relief, alleging ineffective assistance of trial counsel, in part, for counsel’s failure to object to a supplemental jury instruction on the definition of “intentionally” that was given after deliberations had begun. The post-conviction court denied relief. The Supreme Court affirmed, holding that the instruction represented a correct statement of the law, and therefore, trial counsel in this case did not render ineffective assistance in failing to object to the instruction. View "Campbell v. State" on Justia Law

A seventeen-year-old high school student with Down Syndrome choked to death during lunchtime in the school cafeteria. The parents of the child sued the school and several administrators, alleging negligence, wrongful death, and federal civil rights violations. The trial court granted summary judgment for Defendants. The Supreme Court reversed, holding (1) the trial court erred by granting Defendants’ motion for summary judgment on the issue of Plaintiffs’ compliance with the Indiana Tort Claims Act (ITCA) notice requirement, as material issues of fact remained as to whether Plaintiffs complied with the ITCA notice requirement; and (2) Plaintiffs’ state law claims for negligence and wrongful death were not ripe for summary judgment. View "Lyons v. Richmond Cmty. Sch. Corp." on Justia Law

After a jury trial, Defendant was convicted on multiple counts of child molesting, child solicitation, and possession of child pornography. Defendant sought appellate review of the trial court’s denial of his motions to strike three prospective jurors for cause. The central issue before the Supreme Court was Indiana’s exhaustion rule, under which parties may seek appellate review of for-cause challenges to prospective jurors only if they have exhausted their peremptory challenges. The Supreme Court affirmed Defendant’s conviction, holding (1) parties satisfy the exhaustion rule the moment they use their final peremptory challenge, regardless of whom they strike; (2) where parties comply with the exhaustion rule, appellate courts may review denial of any motion to strike for cause, regardless of whether a challenged juror actually served on the jury; and (3) Defendant preserved appellate review of three for-cause challenges, but the trial court did not abuse its discretion by denying all of them. View "Oswalt v. State" on Justia Law

While responding to a report of dogs fighting in Defendant’s backyard, law enforcement officers entered Defendant’s house to retrieve one bloody and aggressive dog and to ensure no one was injured. Once inside the home, the officers found marijuana plants. Based on the evidence found in Defendant’s home, Defendant was charged with five Class D felonies. Defendant moved to suppress the evidence, arguing that the search violated his rights under the federal and state Constitutions. The trial court denied Defendant’s motion and found him guilty of all charges. The court of appeals affirmed, concluding that exigent circumstances justified the officers’ warrantless entry into Defendant’s home. The Supreme Court granted transfer and reversed the trial court, holding that the officers’ entry into Defendant’s home was unreasonable and therefore impermissible under the Indiana Constitution, and therefore, the trial court erred by admitting the evidence recovered from Defendant’s home. View "Carpenter v. State" on Justia Law

Petitioner was fired from her job at the Indiana Department of Workforce Development for alleged misconduct. After it was discovered that Petitioner kept several items of state property in her possession, Petitioner was charged with theft. The charges were later dismissed. Thereafter, the State filed an ethics proceeding against Petitioner, alleging that she violated 42 Ind. Admin. Code 1-5-12. After an adjudicative hearing, the Indiana State Ethics Commission found that Petitioner did commit the alleged violation and barred her from future State executive branch employment. The Supreme Court affirmed the Commission’s decision, holding (1) double jeopardy did not bar the proceeding before the Commission, and the criminal court’s probable cause determination was not binding upon the Commission; (2) there was sufficient evidence to support the Commission’s determination; and (3) the sanction imposed in this case was within the Commission’s discretion. View "Ind. State Ethics Comm’n v. Sanchez" on Justia Law

Plaintiffs sued Defendants for fraudulently failing to disclose defects in a home on a sales disclosure form. The trial court awarded compensatory damages but not fees, costs, or exemplary damages under the Crime Victims Relief Act (CVRA). Plaintiffs moved to correct error, asserting that the court was required to award fees and costs because they had established the CVRA predicate crime of deception. The trial court denied the motion. The Supreme Court affirmed, holding that the trial court acted within its discretion in compensating Plaintiffs for their common-law damages but refusing to award attorney fees or exemplary damages under the CVRA, as Plaintiffs’ complaint encompassed multiple alternative theories of liability not limited to the CVRA, and a court need not impose CVRA liability when it believes ordinary tort liability will do. View "Wysocki v. Johnson" on Justia Law

At issue in this case was whether the certificates of death that doctors, coroners, and funeral directors file with county health departments under Ind. Code 16-37-3 are public records that the public may freely obtain from county health departments. In 2012, Rita Ward sent a letter to the Vanderburgh County Health Department requesting certain copies of records created under Ind. Code 16-37-3-3 and maintained by the Department. The Department denied the request. The Evansville Courier & Press newspaper subsequently requested access to certain Vanderburgh County death records. The Department denied the request. Thereafter, Ward and the Courier & Press sued the Department, arguing that the death certificates were public records covered by the Indiana Access to Public Records Act. The trial court entered judgment in favor of the Department. The Supreme Court reversed, holding that death certificates are public records that a county health department must provide public access to under the Act. View "Evansville Courier & Press v. Vanderburgh County Health Dep’t" on Justia Law