Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with murder and criminal gang activity. During trial, the trial court excused a juror from the jury after she disclosed that she had a frightening experience at her apartment and that she could not render an impartial verdict. The trial court denied Defendant’s motion for a mistrial, concluding that the juror’s incident was unrelated to Defendant’s case and that the jury could remain impartial. The jury subsequently found Defendant guilty of murder and criminal gang activity. The Supreme Court affirmed the trial court’s denial of Defendant’s motion for a mistrial, holding (1) defendants are entitled to a rebuttable presumption of prejudice when they can show by a preponderance of the evidence that an unauthorized, extra-judicial contact or communication with jurors occurred and that the contact or communication pertained to the matter before the jury; and (2) Defendant in this case was not entitled to the presumption of prejudice because he failed to prove that the juror’s extraneous contact and communications related to his case. View "Ramirez v. State" on Justia Law

After a jury trial, Defendant was found guilty of class C felony burglary. The trial court sentenced Defendant to five years in the Indiana Department of Correction, enhanced by eight years for the finding that Defendant was a habitual offender. On appeal, Defendant challenged the sufficiency of the evidence supporting his conviction, arguing that it was unreasonable to infer that he committed the burglary “simply because a glove containing his DNA was found at the scene of the crime.” The Supreme Court affirmed, holding that there was substantial evidence of probative value from which the jury could reasonably infer that Defendant was guilty of burglary beyond a reasonable doubt. View "Meehan v. State" on Justia Law

At issue in this case was Ind. Code 6-1.1-24-3(b), which provides that a mortgagee annually request by certified mail a copy of notice that a parcel of real property is eligible for sale under the tax sale statutes. Here a bank, which held a mortgage on certain property, failed to submit a form affirmatively requesting from the county auditor to mail notice of a pending sale of the real property. Therefore, the bank was not notified that its mortgaged property was tax delinquent until after the property had been sold and the buyer requested a tax deed. The buyer filed a petition to direct the county auditor to issue a tax deed for the property, and the bank filed a response challenging the tax sale notice statutes as unconstitutional under the Fourteenth Amendment. The trial court issued an order holding that the statute was unconstitutional and denying the buyer's petition. The court of appeals affirmed. The Supreme Court reversed, holding that section 6-1.1-24-3(b) was constitutional under the due process clause of the Fourteenth Amendment. Remanded.View "M & M Inv. Group, LLC v. Ahlemeyer Farms, Inc." on Justia Law

Mother and Father were married in 1992 and had two children. The parties later divorced. In 2009, Mother and Father agreed to recalculate their support obligation annually using the Child Support Rules and Guidelines. However, the agreement's terms were silent about which version of the Guidelines applied. Importantly, the Guidelines were amended in 2010, and the changes significantly increased support obligations for high-income parents like Father. Father used the 2009 Guidelines when calculating his 2010 distribution clause payment, and Mother objected. The trial court interpreted the agreement as incorporating the version of the Guidelines that applied to a particular's income, and therefore, concluded that Father should have used the 2010 Guidelines for the 2010 calculation, though he correctly applied the 2009 Guidelines to his 2009 income. Both parties appealed. The Supreme Court affirmed the trial court, concluding that the agreement incorporated each year's version of the Guidelines as to that year's income.View "Schwartz v. Heeter" on Justia Law

Appellant pled guilty to murder, murder in the perpetration of a robbery, and robbery. Appellant sentenced to life imprisonment without parole. The Supreme Court subsequently issued an order directing the trial court to revise the sentencing order to comport with precedent and to clarify whether the trial court relied on non-capital aggravators when imposing sentence. The trial court issued a revised sentencing order of life without parole. Appellant appealed, arguing that the order was deficient because it improperly relied on non-statutory aggravators as a basis for imposing a sentence of life imprisonment without parole. The Supreme Court affirmed, holding that the order as revised comported with prior case law and was not an abuse of the trial court’s discretion. View "Rice v. State" on Justia Law

In 2005, Appellant was convicted of a sex crime against an adult female. In 2009, Appellant was released to statutorily mandated parole. The conditions of Appellant’s parole prohibited Appellant from having contact with children, even his own, and included a requirement that Appellant participate in, and successfully complete, a state treatment program for sex offenders. Appellant filed suit, seeking a declaratory judgment as to the constitutionality of those parole conditions. The trial court granted summary judgment to Appellant with respect to the conditions involving Appellant’s family but otherwise denied Appellant summary judgment on his other claims. Before the case reached the Supreme Court, the Parole Board conceded that it no longer sought to impose the parole conditions in a manner that would restrict Appellant’s relationships with his children and wife. The Supreme Court (1) concluded that some of Appellant’s parole conditions were impermissible, including the conditions that were aimed at restricting Appellant from being near or associating with children, as there was no evidence that Appellant was a threat to children; (2) found no fault with the remainder of the conditions; and (3) found no constitutional flaw in the state treatment program. View "Bleeke v. Lemmon" on Justia Law

Defendant was one of three men that police officers encountered in a self-storage facility and ordered to the ground. After questioning Defendant about the contents of the black bag he was carrying, Defendant admitted it contained marijuana. A subsequent search revealed methamphetamine and drug paraphernalia. The officers then searched Defendant's car, which contained marijuana and equipment for manufacturing methamphetamine. The trial court denied Defendant's motion to suppress his confession and the evidence found in the black bag and in his car. The court subsequently convicted Defendant of several drug-related offenses. The Supreme Court reversed Defendant's conviction, holding that Defendant's confession and the evidence leading to his conviction were fruits of an unlawful detention, as the officers' initial stop of Defendant and the subsequent warrantless search of Defendant's bag did not satisfy the requirements of the Fourth Amendment. Remanded.View "Clark v. State" on Justia Law

Andrew McWhorter appealed the denial of his petition for post-conviction relief, arguing trial counsel rendered ineffective assistance for failing to object to a flawed voluntary manslaughter jury instruction. The Court of Appeals reversed the judgment, and remanded the case for retrial. On transfer, the Supreme Court also reversed the judgment of the post-conviction court, but concluded that on remand, there was no prohibition for retrial on either voluntary manslaughter or reckless homicide. View "McWhorter v. Indiana" on Justia Law

Plaintiffs obtained a homeowners insurance policy from American Family Mutual Insurance Company. After Plaintiffs’ home sustained substantial fire damage, a dispute arose regarding the amount of insurance claim benefits payable under the policy. Plaintiffs subsequently filed a complaint against American Family and Michael Meek, the insurance agent through whom they obtained their insurance, for negligence. The trial court granted summary judgment for Defendants, concluding that Plaintiffs failed to commence the action within the applicable statute of limitations. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court was correct to grant summary judgment on the basis of the applicable two-year statute of limitations. View "Groce v. Am. Family Mut. Ins. Co." on Justia Law

After a jury trial in 1995, Defendant was found guilty of rape, criminal deviate conduct, and armed robbery. Defendant’s aggregate sentence was imposed in such a way that one of the individual sentences was ordered partially concurrent to the other sentences and partially consecutive. Defendant spent the next decade pursuing relief through an appeal, a petition for post-conviction relief, a petition for a writ of habeas corpus, and a motion for sentence modification, all to no avail. Defendant subsequently filed a motion to correct an erroneous sentence, claiming that the trial court lacked the statutory authority to impose a partially consecutive sentence. The trial court denied Defendant’s motion. The Supreme Court reversed and remanded to the trial court for resentencing, holding that the trial court was not statutorily authorized to impose a partially consecutive sentence like the one Defendant received. View "Wilson v. State" on Justia Law