Justia Indiana Supreme Court Opinion Summaries

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

Buyers agreed to buy a condominium from Seller pursuant to a purchase agreement. Buyers demanded that Seller fix a minor electrical problem as a condition of purchase, which led to this protracted litigation. In the first appeal, the court of appeals concluded that Buyers breached the contract with their unreasonable demand and remanded for the trial court to determine damages. The trial court awarded Seller $93,972 in damages. Seller appealed, arguing that she reasonably mitigated her damages and that the trial court erred in calculating damages. Buyers cross-appealed. The court of appeals reversed and awarded only $117 in damages, concluding that Seller could have avoided all damages except a $117 repair bill if she had responded to Buyers’ demand to fix the electrical problem, thus preserving the agreement. The Supreme Court granted transfer and affirmed the trial court, holding that the trial court did not abuse its discretion (1) by finding that Seller could have mitigated her damages by selling her condo in 2007 rather than waiting until 2011; and (2) in refusing to find that Seller’s duty to mitigate required yielding to the Buyers’ breach. View "Fischer v. Heymann" on Justia Law

After K.W., a minor child, was removed from the care of Mother and Father, the Department of Child Services (DCS) sought to terminate the parental rights of Mother and Father. On the day of the termination hearing, Mother’s attorney sought a continuance based on Mother’s incarceration in a local jail. The trial court denied the motion and held a termination of parental rights (TPR) hearing in Mother’s absence. The court then issued an order terminating the parental rights of Mother and Father with respect to K.W. The Supreme Court vacated the portion of the trial court’s order terminating Mother’s parental rights, holding that the trial court, under the facts of this case, abused its discretion by denying Mother’s motion to continue the TPR hearing and by proceeding without her participation. View "In re Involuntary Termination of the Parent-Child Relationship of K.W. and C.C." on Justia Law

After a jury trial, Defendant was convicted of murder and of being a habitual offender. The trial court sentenced Defendant to life in prison. Defendant appealed, arguing that the trial court erred in admitting certain evidence and in giving the jury an erroneous limiting instruction. The Supreme Court affirmed, holding (1) the trial court did not err by admitting certain photographs into evidence; (2) the trial court did not err in allowing the introduction of testimony from a state witness; (3) the trial court did not err in admitting evidence of other crimes; and (4) although the trial court erred in giving a limiting instruction directed to the testimony of a witness, the error was not fundamental.View "Halliburton v. State" on Justia Law

After a bench trial, Defendant was convicted of Public Intoxication as a class B misdemeanor. The court of appeals reversed the conviction, concluding that the evidence was insufficient to establish that Defendant had endangered himself or others, one of the statutory elements for Public Intoxication. The Supreme Court granted transfer to consider whether proof of the endangerment element can be established by reasonable inferences drawn from the evidence. The Supreme Court affirmed the trial court, holding that a reasonable fact-finder could find Defendant had been intoxicated in a public place while endangering the life of himself or others beyond a reasonable doubt based on the evidence and the reasonable inferences drawn therefrom. View "Thang v. State" on Justia Law

Defendant pleaded guilty to B-felony burglary and lesser offenses as part of a combined plea agreement. The agreement conferred discretion to determine the placement of Defendant’s executed sentence but had no provision for further restrictive placement for additional suspended time as a condition of probation. The trial court sentenced Defendant to a total of fifteen years for the burglary with five suspended and two of the suspended years served on probation. The court further ordered that the first year of Defendant’s probationary period be spent through work release. The Supreme Court reversed, holding (1) Defendant’s plea agreement conferred discretion on the court to determine the placement of his executed sentence but did not specifically confer discretion over probation; and (2) therefore, Defendant’s one-year term in work release as a condition of probation following the maximum executed term allowing under the agreement exceeded the court’s authority. View "Berry v. State" on Justia Law

Plaintiff was seriously injured when she was hit by a ball while attending a South Shore RailCats baseball game at their home stadium, the U.S. Steelyard. Plaintiff filed negligence and premises liability claims against South Shore Baseball and the Steelyard, alleging that Defendants breached their duty to her because they failed to extend protective netting far enough to protect her. Defendants moved for summary judgment, arguing that Plaintiff was a mere licensee, and therefore, South Shore fulfilled its duty to warn her of latent dangers. The trial court denied Defendants’ motion for summary judgment. The Supreme Court reversed, holding that Defendants were entitled to summary judgment on Plaintiff’s claims. View "S. Shore Baseball, LLC v. DeJesus" on Justia Law

Appellant was charged with Resisting Law Enforcement by fleeing after being ordered to stop by a law enforcement officer. After a bench trial, the trial court found Appellant guilty of the charge. On appeal, Appellant argued that the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) the statute defining the offense of Resisting Law Enforcement by fleeing after being ordered to stop must be understood to require that a law enforcement officer’s order to stop be based on reasonable suspicion or probable cause; and (2) under the circumstances of this case, there was not sufficient evidence to prove the element that the officer’s order to stop rested on probable cause or reasonable suspicion. View "Gaddie v. State" on Justia Law

Appellant was found to have violated the terms of his probation by committing Resisting Law Enforcement as a Class A misdemeanor by fleeing. The trial court ordered Appellant to serve three-and-one-half years of his previously suspended sentence. On appeal, Appellant argued that the evidence was insufficient to support the revocation of his probation. The court of appeals affirmed. The Supreme Court granted transfer and affirmed based on the reasoning used in its decision in Gaddie v. State, holding that substantial evidence of probative value supported the trial court’s conclusion that Appellant committed Resisting Law Enforcement. View "Murdock v. State" on Justia Law