Justia Indiana Supreme Court Opinion Summaries

After Jerramy Johnson, the owner of Front Row Motors, LLC, sold Scott Jones a used car, Jones filed an action against Front Row Motors, alleging, inter alia, a violation of the Indiana Deceptive Sales Act. Jones subsequently filed an amended complaint adding Johnson as a party defendant. The trial court awarded damages in favor of Jones and against Johnson and Front Row Motors jointly and severally. Defendants moved to set aside the default judgments for imperfect service of process. The trial court set aside the default judgment as against Johnson but denied the motion as to Front Row Motors. The Supreme Court reversed, holding that the trial court abused its discretion in denying Front Row Motors’ motion to set aside the judgment, as Front Row Motors did not receive proper notice of the damages hearing, and therefore, the default judgment entered against it was void for want of jurisdiction. View "Front Row Motors, LLC v. Jones" on Justia Law

After Defendant, a high school principal, was told by a student at his school that she had been raped by a fellow student, Defendant did not notify law enforcement or the Department of Child Services for four hours. Defendant was subsequently convicted for failing to immediately report an instance of suspected child abuse occurring within his institution to the police or the Department. Defendant appealed, claiming that the evidence was insufficient to sustain his conviction and that the criminal statute was unconstitutionally vague. The court of appeals reversed, concluding that the State failed to present sufficient evidence that Defendant had reason to believe the student had been a victim of child abuse as required by the reporting statute. The Supreme Court vacated the court of appeals’ judgment and affirmed the conviction and sentence, holding that none of the possible reasons for Defendant’s failure to report the instance of child abuse were acceptable excuses under the Indiana Code. View "Smith v. State" on Justia Law

The County Department of Child Services filed a petition to involuntarily terminate the parental rights of Father to his child. At the conclusion of the termination hearing, the magistrate that presided over the hearing resigned her position before reporting recommended factual findings and conclusions to Judge Marilyn Moores. The case was subsequently transferred to Magistrate Larry Bradley, who reviewed the hearing record and reported recommended findings and conclusions without holding a new evidentiary hearing. Judge Moores approved the findings and conclusions and terminated Father’s parental rights. The court of appeals affirmed. The Supreme Court reversed, holding that where a case is tried to a judge who resigns before determining the issues, a successor judge cannot decide the issues or enter findings without a trial de novo. Remanded. View "In re Involuntary Termination of Parent-Child Relationship of I.P." on Justia Law

The County Department of Child Services filed a petition to involuntarily terminate the parental rights of Mother to her four children. The case was tried to a judge who resigned before reporting recommended findings and conclusions to Judge Marilyn Moores. The case was transferred to Magistrate Larry Bradley, who reviewed the hearing record and reported recommended findings and conclusions without holding a new evidentiary hearing. Judge Moores approved the findings and conclusions and terminated Mother’s parental rights. The Supreme Court reversed the trial court’s judgment, holding that, in accord with In re I.P., also decided today, the procedure used in this case violated Mother’s due process rights. Remanded. View "In re Involuntary Termination of Parent-Child Relationship of S.B." on Justia Law

A law enforcement officer stopped the vehicle Defendant was driving after observing the vehicle driving under the speed limit and coming to a full stop before turning onto a county road, where Defendant drove left of center. Defendant was subsequently charged with operating a vehicle while intoxicated and with an alcohol concentration equivalent of 0.08 or more. The trial court granted Defendant’s motion to suppress on the ground that the officer lacked reasonable suspicion to initiate the traffic stop, taking judicial notice of the poor condition of the county’s roads, which required “evasive action” on the part of drivers. The Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress, holding that, under these circumstances, the trial court did not clearly err in concluding that Defendant’s driving left of center did not provide reasonable suspicion to stop him. View "State v. Keck" on Justia Law

Defendant was charged with four misdemeanors after a law enforcement officer stopped her vehicle for “unsafe lane movement,” conducted field sobriety tests on Defendant, which she failed, and discovered marijuana concealed in Defendant’s clothing. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to justify the stop. The trial court denied Defendant’s motion, concluding that, while a video from the officer’s vehicle did not show Defendant’s vehicle leaving the roadway, it did show Defendant’s vehicle veering onto the white fog line, and to the extent the officer’s testimony conflicted with the video, the testimony was more reliable than the video. The Supreme Court affirmed, holding that, under the totality of the circumstances, the officer’s conduct was reasonable, and the stop was constitutional. View "Robinson v. State" on Justia Law

In 2005, Plaintiff was robbed and murdered inside his room in a motel owned by Defendant. Joseph Pryor confessed to robbing and killing Plaintiff and was sentenced to eighty-five years in prison for these crimes. In 2007, Plaintiff's estate filed a complaint against Defendant, alleging that Defendant breached his duty to Plaintiff to maintain the motel in a reasonably safe manner. The jury apportioned the fault for Plaintiff's death as follows: one percent to Plaintiff, two percent to Defendant, and ninety-seven percent to Pryor. The Estate subsequently filed a motion to correct error and for a new trial. The trial court ordered a new trial limited to the issue of fault allocation but summarily denied the remainder of the Estate's motion, including the trial court's alleged errors of permitting the jury to allocate fault to Pryor and rejecting the Estate's tendered instruction that would have informed the jurors they could find Defendant liable for Pryor's criminal act. The Supreme Court affirmed, holding that the trial court did not err in permitting the jury to allocate fault to Pryor and in refusing the Estate's tendered instruction that would have permitted the jury to hold Defendant liable for Pryor's intentional act.View "Santelli v. Rahmatullah" on Justia Law

Defendant pleaded guilty to driving while suspended as a habitual traffic violator (HTV). Defendant later filed a petition for post-conviction relief challenging an underlying offense for operating a vehicle while intoxicated (OWI) on grounds of the trial judge's alleged impropriety and the alleged violation of his right to counsel. The post-conviction court vacated the OWI conviction based on impropriety on the part of the trial judge. Defendant subsequently filed a motion to set aside his guilty plea because the OWI underlying offense had been set aside. The trial court granted the motion, set aside the guilty plea, and ordered Defendant's conviction expunged from his record. The Supreme Court affirmed, holding (1) although a defendant who pleads guilty to driving while suspended as a HTV may not later challenge the plea contending that an underlying offense has been set aside on grounds of procedural error, the defendant may be entitled to relief where an underlying offense has been set aside on grounds of material error; and (2) the State failed to meet its burden of demonstrating the trial court clearly erred in granting Defendant's motion to withdraw his guilty plea.View "State v. Oney" on Justia Law

Petitioner was charged with felony rape and related charges. Petitioner's case was first tried to a jury in 2008. The jury deadlocked on Petitioner's charges for felony rape and felony confinement, and a retrial was scheduled. After a second bench trial, the trial court found Defendant guilty of felony rape and not guilty of criminal confinement. The court of appeals affirmed. Petitioner's convictions were affirmed on appeal. Petitioner subsequently filed a petition for post-conviction relief, alleging, inter alia, that his trial counsel was ineffective for failing to object and/or move for a dismissal of the rape charge on state double jeopardy grounds. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) the "actual evidence" test announced in Richardson v. State is applicable to cases in which there has been an acquittal on one charge and retrial on another charge after a hung jury; and (2) the post-conviction court properly denied Petitioner's petition.View "Garrett v. State" on Justia Law

Plaintiff suffered injuries in a collision with Jolene Wright, who was employed by South Central Community Action Program, Inc. Plaintiff and South Central's liability insurer attempted to settle, but settlement efforts failed. Plaintiff later sued Wright and South Central for personal injury damages. Defendants asserted the affirmative defense that South Central was a political subdivision subject to the Indiana Tort Claims Act (ITCA) and that Plaintiff failed to comply with the ITCA notice requirement. The trial court granted summary judgment in Defendants' favor. Plaintiff appealed, citing several reasons to excuse his failure to comply with the notice requirements of the ITCA, including waiver, substantial compliance, agency, and estoppel. The Supreme Court reversed, holding that genuine issues of material fact remained as to whether South Central should be estopped from asserting its ITCA notice defense. Remanded.View "Schoettmer v. Wright" on Justia Law