Justia Indiana Supreme Court Opinion Summaries

Defendant, a non-native English speaker, pleaded guilty to one count of delivery of cocaine within one thousand feet of a school. Ten years later, Defendant filed a petition for post-conviction relief alleging that his plea was not entered knowingly, intelligently and voluntarily because the court-appointed interpreted failed to accurately translate Defendant’s Boykin rights. The post-conviction court denied relief. The court of appeals affirmed, determining that the advisement was defective but, nonetheless, Defendant knew at the time of the plea hearing that he was waiving his Boykin rights. The Supreme Court reversed, holding that Defendant was not properly advised of the constitutional rights he was waiving by pleading guilty and did not understand his constitutional rights when he purportedly waived them. View "Ponce v. State" on Justia Law

Plaintiff was a resident of the City of Logansport and a ratepayer to the municipal utility that supplied her electricity. Plaintiff filed a petition against the City of Logansport, including the City's mayor and common council, seeking a declaration that Ordinance 2013-07, which gave the mayor the authority to enter into a public-private partnership and to negotiate an agreement with an entity that could construct, operate, and maintain a public electric facility and transfer it back to the City, was invalid because the City lacked the authority to pass the ordinance. The trial court dismissed the petition for failing to state a claim upon which relief can be granted. The Supreme Court affirmed, holding (1) Indiana's Public-Private Agreements Act, which authorizes and provides guidelines for the implementation of public-private partnerships, does not require a local legislative body to first adopt the statute before it may issue a request for proposals or begin contract negotiations as provided for under the statute; and (2) the City complied with the Act in every particular, and therefore, Plaintiff was not entitled to relief.View "Kitchell v. Franklin" on Justia Law

After a jury trial, Defendant was convicted of resisting law enforcement, battery of a law enforcement officer resulting in injury, and disorderly conduct. The court of appeals affirmed. Defendant appealed, arguing that the trial court erred in giving only the pattern jury instruction regarding the defense of another and not his tendered jury instructions. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in refusing to give Defendant's tendered instructions, as the Indiana Pattern Jury Instruction is a correct statement of the law and continues to serve as the primary guide for trial judges on the issues of self-defense or defense of another. Remanded to the trial court to correct the abstract of judgment.View "Washington v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and class B felony possession of a firearm by a serious violent felon (SVF). Defendant appealed, claiming (1) the trial court should have given his tendered jury instruction on self-defense, and (2) the trial court erred by not completely bifurcating the trial on his SVF charge from the trial on his murder charge. The Supreme Court affirmed Defendant's convictions, holding that the trial court did not err (1) in utilizing the existing Indiana Pattern Jury Instruction on self-defense and in refusing to give Defendant's tendered jury instruction; and (2) in partially bifurcating the trial. View "Russell v. State" on Justia Law

In November 2006, The Good Samaritan Home, a nursing home where Venita Hargis was living, told Hargis’s family that Hargis had suffered a fall. Hargis died later that month as a result of the injury she sustained in the alleged fall. In November 2009, Hargis’s family discovered that Hargis’s injury had been caused by an attack from another resident and not by a fall. In October 2011, Hargis’s Estate filed a wrongful death complaint against Good Samaritan, alleging that Good Samaritan negligently caused Hargis’s death and then fraudulently concealed its negligence. Good Samaritan filed a motion to dismiss the complaint due to the Estate’s failure to file the action within two years of Hargis’s death. The trial court dismissed the complaint, concluding that fraudulent concealment does not extend or delay the two-year statutory period to file a wrongful death action. The Supreme Court reversed, holding that if a plaintiff makes the necessary factual showing, the fraudulent concealment statute may apply to toll the Wrongful Death Act’s two-year filing period. View "Alldredge v. Good Samaritan Home, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of felony sexual misconduct with a minor. Defendant appealed, arguing that several statements made by the State during closing argument constituted prosecutorial misconduct. Because Defendant did not raise any objection to the prosecutor’s remarks during trial, Defendant contended that the remarks cumulatively resulted in fundamental error. The court of appeals agreed with Defendant and reversed his convictions. The Supreme Court granted transfer, thereby vacating the court of appeals, and affirmed the judgment of the trial court, holding (1) the prosecutor engaged in one instance of misconduct; but (2) because of the absence of any timely objection by Defendant, reversal was not warranted. View "Ryan v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown, robbed two victims in their home. The victims were killed during the robbery. Brown was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Brown to an aggregate sentence of 150 years, the same sentence imposed on Brown’s cohorts. The Supreme Court revised the 150-year sentence received by Brown, holding that Brown’s sentence “foreswears altogether the rehabilitative ideal,” and concluded that Brown should be sentenced to an enhanced sentence to a total aggregate sentence of eighty years imprisonment. View "Brown v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown and fifteen-year-old Defendant, robbed two victims in their home. The victims were killed during the robbery. Defendant was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Defendant to an aggregate sentence of 150 years, the same sentence imposed on Brown. The Supreme Court revised the 150-year sentence received by Brown and similarly exercised its constitutional authority to revise Defendant’s sentence, holding that Defendant’s sentence “foreswears altogether the rehabilitative ideal” and concluding that Defendant should total aggregate sentence of eight-five years imprisonment. View "Fuller v. State" on Justia Law

Plaintiff, an Indiana resident, was driving a semi-tractor trailer on behalf of Werner Transportation, a Georgia company, when he was injured in West Virginia after another truck hit his rig. Werner insured the truck under a policy from Empire Fire and Marine Insurance Co., which provided $5 million liability coverage. Empire, however, claimed that the policy included only $75,000 in underinsured motorist coverage. Applying Georgia law, the trial court granted summary judgment in favor of Empire, finding there was sufficient evidence that Werner made the affirmative choice to purchase underinsured motorist coverage in a lower amount than the liability policy limit. The court of appeals determined that Indiana law applied but nonetheless affirmed the trial court, concluding the evidence was sufficient under Indiana law to establish that Werner had explicitly rejected the default $5 million coverage limit and instead purchased coverage only in the amount of $75,000. The Supreme Court reversed, holding that the issue of whether Werner waived the higher liability limit for underinsured motorist insurance was “unsuitable for summary judgment and best left to the fact-finder.” View "Asklar v. Gilb" on Justia Law

Decedent died on March 25, 2011 from cervical cancer. On July 1, 2011, Decedent's Estate commenced this medical malpractice action, alleging that Defendant, Decedent’s physician, had negligently failed to perform a recommended endocervical biopsy and that this mistake led to a late diagnosis of Decedent’s cancer and ultimately resulted in her death. Defendant filed a motion for summary judgment on statute of limitations grounds because the complaint was filed more than two years after Defendant allegedly failed to perform the endocervical biopsy. The trial court granted the motion. The Supreme Court reversed, holding that there remained a genuine issue of material fact as to whether the Estate filed its complaint within a reasonable time, and therefore, Defendant was not entitled to summary judgment. View "David v. Kleckner" on Justia Law