Justia Indiana Supreme Court Opinion Summaries

On April 19, Plaintiff sent a proposed medical malpractice complaint to the Indiana Department of Insurance by way of FedEx Priority Overnight. On April 21, the Department received the proposed complaint and filed-stamped it that same day. April 21 was one day after the expiration of the applicable two-year statute of limitations. The trial court granted summary judgment for Defendants, concluding that the proposed complaint was considered “filed” upon receipt rather than upon deposit with a private delivery service. The court of appeals affirmed. The Supreme Court granted transfer and reversed the entry of summary judgment in favor of Defendants, holding (1) the commencement of a medical malpractice action occurs when a copy of the proposed complaint is deposited for mailing by registered or certified mail or by a designated private delivery service; and (2) Plaintiff’s action was deemed filed, and her action commenced, on April 19, which was within the applicable statute of limitations. View "Moryl v. Ransone" on Justia Law

In 2008, one-year-old E.M. and his newborn sister El.M. were adjudicated children in need of services (CHINS) based on father’s repeated domestic violence against Mother. By mid-2010, both Mother and Father had ceased receiving services from the Department of Child Services (DCS), and DSC petitioned to terminate Mother’s and Father’s parental rights. The trial court subsequently terminated Father’s parental rights, and Father appealed. The court of appeals reversed, concluding that the trial court placed too much weight on Father’s past conduct without adequately taking into consideration evidence of changed conditions at the time of the termination hearing. The Supreme Court vacated the court of appeals opinion, holding (1) the court of appeals contravened the standard of review by reweighing the evidence; and (2) the evidence was sufficient to support termination. View "E.M. v. Ind. Dep’t of Child Servs." on Justia Law

Howard Price was the Fayette County Highway Supervisor from 1991 to 2002 and again resumed the position in 2006. In 2011, the Fayette County Board of Commissioners decided not to reappoint Price as Highway Supervisor. Thereafter, Price brought this action requesting a review of the Board’s decision to terminate his continued employment. The Board filed a motion to dismiss, which the trial court treated as a motion for summary judgment, asserting that its employment decision was not subject to judicial review. The trial court denied summary judgment, concluding that the Board’s decision was quasi-judicial in nature and thus subject to judicial review. The court of appeals affirmed on interlocutory appeal. The Supreme Court reversed, holding that the Board’s employment decision with respect to Price was a ministerial decision, not a quasi-judicial one, and therefore not subject to judicial review. View "Fayette County Bd. of Comm’rs v. Price" on Justia Law

From 2002 through 2008, Respondent Kimberly J. Brown served as judge of a small claims court. In 2009, Respondent began serving as judge of the superior court. In 2013, the Indiana Commission on Judicial Qualifications charged Respondent with violations of the Code of Judicial Conduct, conduct prejudicial to the administration of justice, and acts of willful misconduct. The charged alleged, among other things, dereliction of judicial duties on cases, creation of a hostile environment for attorneys and others working in the court, and failures to complete necessary paperwork, which resulted in delayed releases of defendants from jail. Three Special Masters appointed by the Supreme Court found that Respondent committed judicial misconduct alleged in forty-six of the forty-seven counts for which Respondent was charged. The Commission concurred in the Masters’ recommendation that Respondent be removed from office. The Supreme Court removed Respondent from the office of judge of the superior court, concluding that the Commission demonstrated, by clear and convincing evidence, that Respondent engaged in significant judicial misconduct and that the misconduct warranted her removal from office. View "In re Brown" on Justia Law

Mary Manley was involved in a head-on automobile collision with Kimberly Zehr. Manley later learned that Zehr had several medical conditions that, combined with medications she had been prescribed by her physician. Dr. Ryan Sherer, may have contributed to the accident. Manley and her husband (Plaintiffs) later filed a proposed complaint with the Indiana Department of Insurance against Dr. Sherer and his medical group (Defendants) alleging medical negligence in failing to warn Zehr not to drive while she was taking her medication. The trial court granted summary judgment in favor of Defendants, concluding that Plaintiffs' action was untimely brought under the two-year limitation period set forth in the Indiana Medical Malpractice Act. The Supreme Court reversed, holding (1) it was indiscernible whether Plaintiffs could have pursued their malpractice claim within the two-year statutory limit, or if not, whether they acted within a reasonable time as required by caselaw; and (2) genuine issues of material fact existed as to the absence of the element of causation necessary to establish liability. Remanded.View "Manley v. Sherer" on Justia Law

Plaintiffs sent a proposed medical malpractice complaint to the Indiana Department of insurance without including $7 in required statutory filing and processing fees. Plaintiffs subsequently filed their medical malpractice complaint against Defendants. After the Department discovered the fee omission, it sent Plaintiffs a letter stating that if the mandatory fee was not sent, the complaint would not be considered filed with the Department. Plaintiffs sent a check to the Department the day they received the letter. The Department received the processing fees three days after the statutory period ended. The trial court subsequently granted summary judgment for Defendants, finding Plaintiffs' complaint was not timely filed. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiffs' proposed complaint was timely filed with the Department.View "Miller v. Dobbs" on Justia Law

Plaintiff, a limited liability corporation, filed a complaint against Defendants - James T. Mitchell individually, the corporation that Mitchell owned, and other corporations - alleging a claim for an environmental legal action and a violation of Indiana’s anti-dumping statute due to Defendants’ alleged environmental contamination while operating certain dry cleaning businesses. The trial court granted partial summary judgment for Mitchell in his individual capacity. Plaintiff filed a motion to vacate the trial court’s order entering partial summary judgment for Mitchell, contending that newly discovered inculpatory evidence established Mitchell’s individual liability. Mitchell opposed the motion, arguing that the newly discovered evidence in this case was not properly designated or timely submitted pursuant to Indiana Trial Rule 56. The trial court granted Plaintiff’s motion, concluding that the order granting partial summary judgment was a non-final order and therefore subject to revision at any time before entry of a final judgment. The Supreme Court reversed, holding that although a trial court may make material modifications to a non-final summary judgment order, it must do so based on the timely submitted materials properly before it when the order was initially entered. View "Mitchell v. 10th and The Bypass, LLC" on Justia Law

The State charged Defendant with class D felony sexual battery. Defendant, who was born in 1943, filed a motion for a competency determination. Doctors evaluating Defendant diagnosed him with dementia, concluded that he was not competent to stand trial, and predicted that he would not be able to be restored to competency. Based on the doctors’ reports and without a hearing, the trial court found that Defendant was not competent to stand trial and that he could not be restored to competency. The State then requested that the court commit Defendant to the Division of Mental Health and Addiction (DMHA) pursuant to Ind. Code 35-36-3-1(b). The trial court denied the motion. The Supreme Court reversed the trial court’s denial of the State’s motion to commit Defendant to the DMHA, holding that section 35-36-3-1(b) requires trial courts to commit defendants found not competent to stand trial to the DMHA for competency restoration services. Remanded. View "State v. Coats" on Justia Law

Plaintiff, a college freshman and a fraternity pledge, sustained injuries in an incident at the fraternity. Claiming that his injuries resulted from a fraternity hazing incident, Plaintiff sought damages from the college, the campus local fraternity, the national fraternity, and one of the fraternity members. The trial court granted summary judgment for the college and the two fraternity organizations. The Supreme Court reversed the grant of summary judgment for the campus fraternity but affirmed the grant of summary judgment for the college and the national fraternity organization, holding (1) the college and the national fraternity were each entitled to judgment as a matter of law; but (2) as to the local fraternity, there remained genuine issues of material fact that precluded summary judgment. Remanded. View "Yost v. Wabash College" on Justia Law

After one of Mother’s five children, a toddler, was rushed to the emergency room and placed on a ventilator, Mother consented to the Department of Child Services (DCS) removing the other four children from her care to let her focus on the toddler’s treatment. DCS initiated child in need of services (CHINS) proceedings over all five of the children based on the toddler’s special medical needs and Mother’s lack of steady housing and other needs for the children. After a fact-finding hearing, the trial court released wardship to Mother’s four oldest children but did find the toddler in need of services because no one in the home had “completed the medical training needed” to meet the toddler’s special medical needs. The Supreme Court reversed the trial court’s judgment that the toddler was a child in need of services, holding that because Mother had voluntarily addressed all but one of DCS’s concerns to the trial court’s satisfaction and because the evidence failed to show that Mother was likely to need the court’s coercive intervention to complete that final item, the trial court abused its discretion in determining that the toddler was a child in need of services. View "In re S.D." on Justia Law