Justia Indiana Supreme Court Opinion Summaries

Defendant was indicted on several charges relating to his divorce case. After a jury trial, Defendant was convicted of one felony count of intimidating the trial judge, two misdemeanor counts of intimidation involving the judge’s wife and a psychologist who was an expert witness in the divorce, and one felony count of attempted obstruction of justice relating to the psychologist. Defendant appealed on free speech grounds. The court of appeals reversed the misdemeanor-level intimidation convictions and affirmed the felony convictions. The Supreme Court granted transfer, affirmed Defendant’s convictions for intimidation of a judge and attempted obstruction of justice, and summarily affirmed the court of appeals on all other counts, holding (1) the court of appeals erred in its free speech analysis by failing to distinguish between Defendant’s attacks on his victims’ reputations, which are protected by the stringent actual malice standard, and Defendant’s true threats to the victims’ safety, which receive no such protection; but (2) there was ample evidence of true threats to support Defendant’s convictions for intimidating the judge and Defendant’s attempted obstruction of justice regarding the psychologist. View "Brewington v. State" on Justia Law

In order to renovate a former warehouse building into administrative offices, Evansville-Vanderburgh School Corporation (“School Corporation”) implemented a plan to convey the Building to the EVSC Foundation (“Foundation”), a private non-profit entity, have the Foundation contract with a contractor for the renovations, and then have the Foundation sell the Building back to the School Corporation. School Corporation officials selected this arrangement because the Foundation was not subject to public bidding laws, and therefore, the renovation could occur more quickly. Plaintiffs, several area contracting businesses paying taxes in the school district, filed an action against the School Corporation and the Foundation (together, “Defendants”) claiming that Defendants violated public bidding statutes and Indiana’s Antitrust Act. The trial court granted Defendants’ motion for summary judgment, determining that the School Corporation engaged in the transactions to circumvent the public bidding statutes but that the transactions were not unlawful. The court of appeals reversed, concluding that the project violated the Public Bidding Laws. The Supreme Court (1) affirmed the portion of the court of appeals’ opinion holding that the scheme used by Defendants violated the Public Bidding Laws; and (2) concluded that Plaintiffs' antitrust claim failed because Plaintiffs did not present evidence of an antitrust injury. View "Alva Elec., Inc. v. Evansville-Vanderburgh Sch. Corp." on Justia Law

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