Justia Indiana Supreme Court Opinion Summaries

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

The Indiana Utility Regulatory Commission (IURC) approved a contract for the purchase of substitute natural gas and directed the procedure for resolving future related disputes. The court of appeals reversed the IURC's approval of the contract because a definition term in the contract deviated from the required statutory definition. The parties to the contract subsequently amended the contract to delete the language that the court of appeals found improper. The Supreme Court vacated the reversal of the IURC's order, held that the amended contract that corrected the definitional error rendered the definitional issue moot, and summarily affirmed the court of appeals as to all other claims.View "Ind. Gas Co., Inc. v. Ind. Fin. Auth." on Justia Law

Mother and Father were divorced in 1999 pursuant to a decree that approved the parties' comprehensive settlement agreement under which Mother was granted physical custody of the parties' two children. In 2011, Father sought to modify the decree. The trial court modified the prior child support order in several respects. Father appealed. The court of appeals reversed, inter alia, the trial court's determination of credits for Mother's health insurance costs and Father's Social Security benefits. The Supreme Court granted transfer and (1) affirmed the trial court on the issues of health insurance costs and Social Security benefits, holding that the trial court's approach was appropriate in this case; and (2) summarily affirmed the court of appeals in all other respects.View "Johnson v. Johnson" on Justia Law

After a bench trial, Defendant was convicted of resisting law enforcement and sentenced to ninety days in jail. Defendant appealed, arguing that the evidence was insufficient to sustain his conviction. In this case, Defendant refused repeated orders to lie down on the ground and aggressively advanced, with his fists clenched, to within a few feet of the police officer issuing the orders before being tased. The Supreme Court affirmed, holding that Defendant's act of aggression toward the officer was sufficient to show that Defendant forcibly resisted, obstructed, or interfered with the law enforcement officer pursuant to Ind. Code 35-44.1-3-1(a)(1). View "Walker v. State" on Justia Law

Upon responding to a call about an unsupervised toddler wandering near an apartment-complex retention pond, Defendant informed the police that he was the child’s father. Defendant consented to police entry into his apartment, and the child’s mother, the leaseholder, consented to a full search. The police officers subsequently discovered contraband in the apartment and charged Defendant with unlawful possession of a firearm by a serious violent felon, neglect of a dependent, dealing marijuana, possessing marijuana, and possession of paraphernalia. Defendant pleaded guilty to the neglect and marijuana-possession counts, and the case proceeded to a trial on the remaining counts. During trial, Defendant filed a motion to suppress evidence found during law enforcement’s pat-down search and subsequent search. The trial court denied the motion. Defendant was acquitted of dealing marijuana but found guilty on the remaining charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, as Defendant consented to police entering the apartment, Defendant’s movements justified a pat-down, and the mother gave her consent to search the rest of the apartment. View "McIlquham v. State" on Justia Law

Plaintiff, a former independent commissioned sales representative for Mor/Ryde International, Inc., sued Mor/Ryde for unpaid commissions under a contract between the parties. One count of Plaintiff’s complaint alleged violations of the Indiana Sales Representative Act. The trial court concluded that the Sales Representative Act applied to Mor/Ryde’s contract with Plaintiff and ruled that exemplary damages under the Sales Representative Act are subject to statutory restrictions on awards of punitive damages. The Supreme Court reversed, holding (1) the Punitive Damages Act applies only to discretionary common-law punitive damages awards, not statutory damage awards like the Sales Representative Act; and (2) therefore, treble damages under the Sales Representative Act are not subject to the Punitive Damages Act. View "Andrews v. Mor/Ryde Int’l, Inc." on Justia Law