Justia Indiana Supreme Court Opinion Summaries

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

After Plaintiffs’ eighteen-year-old son, a freshman pledge of a college fraternity, died from acute alcohol ingestion, Plaintiffs brought a wrongful death action against the national fraternity, the local fraternity, and the college. The trial court granted summary judgment for the national fraternity. The Supreme Court affirmed the judgment of the trial court, holding that the trial court did not err in (1) denying Plaintiffs’ motion to strike an affidavit and two purported interview transcriptions designated as evidentiary material by the national fraternity; and (2) entering summary judgment for the national fraternity, as the national fraternity did not have a duty to insure the safety of the freshman pledges at the local fraternity and was not subject to vicarious liability for the actions of the local fraternity, its officers, or its members. View "Smith v. Delta Tau Delta, Inc." on Justia Law

Upon the divorce of Mother and Father, Father was awarded physical custody of the parties' two children. Five years later, Mother filed a motion to modify actual physical custody of both children. Without an evidentiary hearing, the trial court summarily granted Mother's motion to modify custody and awarded custody of the two children to Mother. On appeal, Father argued that the trial court erred in modifying the prior custody order without an evidentiary hearing and without issuing findings regarding the best interest of the children. The Supreme Court vacated the trial court's order, holding that, under the facts and circumstances of this case, the trial court's summary resolution, without a hearing where witnesses could be sworn and testimony heard and without the consent of the parties, was an abuse of discretion. Remanded.View "Wilson v. Myers" on Justia Law

After purchasing a car from Defendant, a car dealership, Plaintiff discovered that the car had extensive problems. Plaintiff sued Defendant, alleging that advertising the car as a "Sporty Car at a Great Value Price" violated the Indiana Deceptive Consumer Sales Act and that the salesperson's representation to her that the car would "just need a tune-up" was fraudulent. The trial court granted summary judgment for Defendant. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court correctly found that Defendant's advertisement was classic puffery, which was fatal to Plaintiff's deception claims; but (2) Plaintiff established an issue of material fact as to her fraud claim based on the salesperson's statements. Remanded.View "Kesling v. Hubler Nissan, Inc." on Justia Law

On September 19, 2011, the trial court sentenced Defendant. On December 5, 2012, Defendant filed a motion to modify her sentence. On March 5, 2013, the trial court granted Defendant’s motion for modification. The State appealed, arguing that the trial court lacked authority to modify Defendant’s sentence because more than 365 days had passed since Defendant was sentenced and the prosecutor did not affirmatively approve of the modification. The Supreme Court affirmed, holding that the trial court did not err in granting Defendant’s motion for sentence modification, where, in the context of the interactions and communications between the trial court and the prosecutor in this case, the prosecutor’s conduct adequately conveyed the “approval of the prosecuting attorney” required in Ind. Code 35-38-1-17(b). View "State v. Harper" on Justia Law

Sara Townsend and A.S. were co-workers. Townsend completed an application to initiate a process to seek immediate emergency treatment for A.S., alleging that A.S. was a threat to herself or others. A trial court judge issued a warrant for A.S.’s detention and treatment. Doctors at the hospital where A.S. was subsequently detained, however, determined that there was no cause to continue detaining A.S. and discharged her. Thereafter, the trial judge found Townsend in contempt of court and imposed sanctions. The court of appeals (1) concluded that the trial court lacked statutory authority to find Townsend in indirect civil contempt, but (2) upheld the trial court’s order directing Townsend to pay A.S.’s hospital bill and attorney fees as a legitimate exercise of the trial court’s inherent powers to issue sanctions. The Supreme Court vacated the court of appeals’ opinion and reversed, holding (1) the trial court lacked the statutory authority to find Townsend in contempt and impose sanctions; and (2) Townsend’s actions did not place her under the trial court’s authority to impose sanctions as an inherent power of the judiciary. View "In re Mental Health Actions for A.S." on Justia Law

After a detective received a tip that Defendant, who was African American, was responsible for a 2007 murder, the detective brought Defendant into an interrogation room to question him about the murder. In order to convince Defendant to admit his guilt, the detective implied during the interrogation that Defendant’s race precluded him from receiving a fair trial and an impartial jury. Defendant confessed to the murder. Defendant filed a motion to suppress his statement, claiming that it was involuntarily given. The trial court denied the motion. The Supreme Court reversed, holding that, in order to induce a confession, a police officer’s tactic of intentionally misleading a suspect as to his constitutionally guaranteed rights to a fair trial and an impartial jury, because of the suspect’s race, renders that confession involuntary. Remanded. View "Bond v. State" on Justia Law

The Indianapolis Marion County City-County Council and Mayor Gregory Ballard agreed on an ordinance dividing Marion County into legislative districts. Three members of the Council (“Plaintiffs”) filed a complaint seeking a declaration that the ordinance failed to comply with the Redistricting Statute for Marion County, which assigns the task of redrawing the County’s legislative districts to the judiciary if the County’s legislative and executive branches become deadlocked over required redistricting. The trial court granted Plaintiffs’ motion for partial summary judgment and then drew new legislative districts, concluding that because the Council divided the County by ordinance in 2011, not during 2012 as required by the Redistricting Statute, the ordinance failed to satisfy the requirement for “mandatory redistricting” during 2012. The Supreme Court reversed, holding that this case did not present a redistricting impasse that required judicial intervention. View "Ballard v. Lewis" on Justia Law