Justia Indiana Supreme Court Opinion Summaries

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

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