Justia Indiana Supreme Court Opinion Summaries

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

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