Justia Indiana Supreme Court Opinion Summaries

The State charged Defendant with three counts of felony nonsupport of a defendant child. By the time the case went to trial, all three children were adults and emancipated. The trial court found Defendant guilty as charged and ordered him to pay the children's mother, "the victim in the case," the amount of his child-support arrearage. The trial court used the term "restitution" at the sentencing hearing. The court of appeals affirmed Defendant's convictions and length of sentence but determined that the court's order for Defendant to pay restitution to the mother as "the victim" was erroneous. The Supreme Court granted transfer and summarily affirmed the court of appeals on all issues but the issue of restitution and held that the trial court was within its discretion to determine that restitution was payable to a custodial parent, despite the fact that the children were emancipated. Remanded. View "Sickels v. State" on Justia Law

A school liaison officer intervened in a hallway scuffle between K.W. and another student. K.W. turned away from the officer's effort to handcuff him. K.W. was subsequently adjudicated delinquent for resisting law enforcement. K.W. appealed, challenging the sufficiency of the evidence. The court of appeals reversed, holding that there was insufficient evidence that the officer was "lawfully engaged in the execution of the officer's duties" as a law-enforcement officer. The Supreme Court granted transfer and reversed the trial court, albeit for different reasons than the court of appeals, holding that the evidence did not establish "force" beyond a reasonable doubt, and without evidence of a "forcible" resistance, K.W.'s delinquency adjudication could not be sustained. View "K.W. v. State" on Justia Law

After a jury trial, Defendant was convicted of criminal mischief as a Class B misdemeanor for vandalizing another man's truck. The trial court sentenced Defendant to thirty days executed, 150 days suspended, and 360 days of probation. The court of appeals (1) affirmed Defendant's conviction, concluding it was supported by sufficient evidence, and (2) reversed in part Defendant's sentence and remanded for a redetermination of Defendant's period of probation, not to exceed 185 days, finding that Defendant's sentence was inconsistent with Ind. Code 35-50-3-1(b). The Supreme Court granted transfer and vacated the opinion below, holding (1) the evidence was sufficient to support Defendant's conviction; and (2) regardless of the maximum sentence available under Ind. Code. 35-50-3-2 through -4, the combined term of imprisonment and probation for a misdemeanor may not exceed one year. Remanded for imposition of a probationary period not to exceed 335 days - the difference between one year and the thirty days Defendant was ordered to serve in prison. View "Jennings v. State " on Justia Law

Defendant, a North Carolina resident, was charged in Indiana with two counts of non-support of a dependent. After the trial date was set, Defendant's public defender filed a motion to withdraw. The trial court granted the motion to withdraw after Defendant failed to appear for a hearing on the motion. Defendant subsequently failed to appear in court the morning of his trial date, so he was tried in absentia. A jury found him guilty on both counts. Defendant arrived at the courthouse that afternoon and was immediately taken into custody. The Supreme Court vacated Defendant's convictions and remanded for a new trial, holding that based on the particular facts and circumstances of this case, the trial court abused its discretion in trying Defendant in absentia, without counsel. View "Hawkins v. State" on Justia Law

When Husband and Wife's marriage was dissolved in 2005, the trial court approved the settlement agreement reached by the parties following mediation. In 2011, Husband sought to modify the agreement. At the evidentiary hearing, the trial court excluded from evidence Husband's testimony regarding statements he claimed to have made to the mediator during mediation. The court subsequently denied Husband's request for modification of his monthly housing payment obligation. The Supreme Court affirmed, holding (1) the trial court was correct to exclude Husband's mediation statements from evidence on his petition to modify the parties' settlement agreement; and (2) the trial court correctly rejected Husband's request for modification of his monthly housing payment obligation. View "Horner v. Carter" on Justia Law

After a bench trial, Defendant was found guilty of burglary, adjudicated an habitual offender, and sentenced to twenty-two years imprisonment. The trial court also ordered Defendant to pay restitution to the victim in the amount of $711.95, which reflected the loss of the victim's television set and record collection. The court of appeals reversed the restitution order on grounds there was insufficient evidence to support the amount awarded and declined to remand the case. The Supreme Court granted transfer to address whether the case could be remanded for a new restitution hearing. The Court granted transfer of jurisdiction and remanded to the trial court with instructions to conduct a new restitution hearing at which the State would be permitted to present, and Defendant would be allowed to confront, any additional evidence supporting the victim's property loss. View "Iltzsch v. State" on Justia Law

Plaintiff's wife died after various physicians failed to diagnose and treat her obstructed bowel. Plaintiff, acting individually and as a personal representative of his wife's estate, filed a medical malpractice complaint against Community Hospitals of Indiana, Inc. (Community). A jury returned a verdict in favor of Plaintiff and awarded damages in the amount of $8.5 million. Community subsequently made an oral motion to reduce the jury awarded to $1.23 million - the cap imposed by the Indiana Medical Malpractice Act (Act). Plaintiff objected to the reduction of the damage award alleging that the cap was unconstitutional and requesting an evidentiary hearing to develop his constitutional challenges. The trial court denied Plaintiff's request and entered judgment in the amount of $1.25 million. The Supreme Court affirmed, holding that Plaintiff forfeited his opportunity to conduct an evidentiary hearing to challenge the constitutionality of the Act. View "Plank v. Cmty. Hosps. of Ind., Inc." on Justia Law

In 1997, Defendant pled guilty to child solicitation, a class D felony. Upon discharge from probation in 1999, Defendant was required to register as a sex offender for ten years pursuant to the Sex Offender Registration Act. In 2006, the legislature amended the Act to require lifetime registration in certain circumstances. Defendant's offense fell within these circumstances. After Defendant had completed ten years of registration, he requested the removal of his registration requirement. The trial court denied the petition. The Supreme Court reversed, holding that, under the facts of this case and as applied to Defendant, the Ex Post Facto Clause of the Indiana Constitution prohibited retroactive application of the lifetime registration requirement. View "Gonzalez v. State" on Justia Law

A steel fabrication company deposited solid waste on a landowner's property, after which the landowner (Plaintiff) filed a complaint seeking damages against multiple parties (Defendants) and on multiple grounds, including a claim for an environmental legal action (ELA). Plaintiff filed a motion for summary judgment on his environmental legal action claim and sought to impose corporate liability on Defendants. Defendants filed cross motions for summary judgment on all of Plaintiff's claims, except for his claim of negligence. The trial court denied Plaintiff's motions and granted Defendants' motions as to all claims, leaving for trial only Plaintiff's negligence claim and the claims of potential liability against Defendants. The Supreme Court affirmed in part and reversed in part, holding that summary judgment was (1) not proper for either party on Plaintiff's ELA claim; (2) not proper for Defendants on Plaintiff's illegal dumping, fraud, nuisance, and trespass claims; (3) proper for Defendants on Plaintiff's unjust enrichment and intentional torts claims; (4) proper for certain defendants on Plaintiff's responsible corporate officer claim but improper as to others; and (5) proper for Plaintiff on his claims against one defendant as responsible corporate officer. View "Reed v. Reid" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of child molesting and sentenced to an aggregate term of eighty years. The court of appeals affirmed Defendant's convictions but remanded the cause to the trial court with instructions to impose an aggregate term of forty years, concluding that the trial court abused its discretion sentencing Defendant. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and summarily affirmed the portion of the court of appeals' decision concerning the majority of Defendant's claims. The Court then affirmed the judgment of the trial court regarding Defendant's sentence, holding that the trial court did not abuse its discretion in imposing Defendant's sentence. View "Kimbrough v. State" on Justia Law