Justia Indiana Supreme Court Opinion Summaries

Patients Abby Allen and Walter Moore sought medical treatment at Clarian North Hospital, which was owned by Clarian Health Partners. After Allen, who was uninsured and not covered by Medicare or Medicaid, received services, the hospital billed Allen its "chargemaster" rates in accordance with a contract between Allen and Clarian. Patients' class action complaint alleged breach of contract and sought declaratory judgment that the rates the hospital billed its uninsured patients were unreasonable and unenforceable. The trial court granted Clarian's motion to dismiss for failure to state a claim upon which relief can be granted. The court of appeals reversed, concluding that the issue of reasonableness required resolution by a fact-finder. The Supreme Court vacated the opinion of the court of appeals and affirmed the judgment of the trial court, holding that Patients' agreement to pay the hospital for the medical services they received in the context of a contract they formed with Clarian was not indefinite and referred to Clarian's chargemaster. As a result, the Court could not impute a "reasonable" price term into the contract. View "Allen v. Clarian Health Partners, Inc." on Justia Law

After Plaintiff experienced dizziness and difficulty walking, she was admitted into a medical clinic (Clinic) and seen by the on-duty physician (Doctor). Doctor diagnosed Plaintiff with vertigo. Two days later, Plaintiff was unable to move her right arm or leg and was later diagnosed with having suffered a stroke. Defendant subsequently filed a complaint alleging negligence by Doctor and Clinic (collectively, Defendants) for the failure to diagnose a transient stroke. After a jury trial, the trial court entered judgment in favor of Plaintiff in the amount of $1.25 million but denied Plaintiff's motion for prejudgment interest. The court thereafter denied Defendants' motion for a new trial based upon the cumulative effect of Plaintiff's counsel's alleged unprofessional conduct during the trial. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendants' motion for a new trial, despite Plaintiff's counsel's dissatisfying behavior; and (2) denying the discretionary award of prejudgment interest. View "Wisner v. Laney" on Justia Law

After an automobile collision involving Driver, Plaintiff sued Driver. When Driver passed away, Plaintiff amended her complaint to substitute the Administrator of Driver's estate. A jury found in favor of Plaintiff and awarded her $210,000 in damages. Plaintiff subsequently filed a motion asking the trial court to award her prejudgment interest pursuant to the Tort Prejudgment Interest Statute (TPIS). The trial court enied Plaintiff's motion because her damages were not ascertainable within a time frame that justified an award of prejudgment interest. The Supreme Court reversed, holding (1) the TPIS abrogates and supplants the common law prejudgment interest rules in cases covered by the statute; and (2) Plaintiff's motion for prejudgment interest should have been evaluated as provided in the statute and not on abrogated common law. Remanded for reconsideration of the motion. View "Kosarko v. Padula" on Justia Law

Plaintiff's vehicle was rear-ended by Driver's vehicle. Plaintiff sued Driver and settled with his insurer for $50,000, the maximum of Driver's automobile liability policy. Plaintiff then sought an additional $50,000 under her underinsured motorist (UIM) policy with State Farm. State Farm declined to award the requested amount. Following trial, the jury returned a verdict in favor of Plaintiff in the amount of $50,000. The trial court declined Plaintiff's motion for prejudgment interest pursuant to the Tort Prejudgment Interest Statute (TPIS). Plaintiff appealed the trial court's denial of her motion for prejudgment interest. The Supreme Court affirmed, holding (1) the TPIS does apply to UIM coverage disputes; (2) because prejudgment interest is a collateral litigation expense, it can be awarded in excess of an insured's UIM policy limits; but (3) Plaintiff was not entitled to prejudgment interest because the trial court acted within its discretion when it denied her request for prejudgment interest. View "Inman v. State Farm Mut. Auto. Ins. Co." on Justia Law

The day after thirteen-month-old I.A. underwent surgery performed by Defendant, I.A. died. Plaintiff, I.A.'s mother, filed a medical malpractice claim against Defendant. After a jury trial, Defendant was held liable in the amount of $1,165,000. The trial court denied Plaintiff's request for pre-judgment interest. Defendant appealed, raising three allegations of error, and Plaintiff cross-appealed the denial of her request for prejudgment interest. The Supreme Court summarily affirmed the court of appeals opinion relating to Defendant's issues but reversed the trial court's decision to deny Defendant prejudgment interest based upon a defective settlement letter, holding (1) Defendant's settlement letter did comply with Ind. Code 34-51-4-6; and (2) the award of prejudgment interest is neither automatic nor required and is left to the discretion of the trial court. Remanded. View "Alsheik v. Guerrero" on Justia Law

An encounter between a tenured professor at a private university and his department head turned into a formal complaint of harassment against the professor. After extensive internal proceedings, the professor's tenure was rescinded and he was dismissed from the university's faculty. The professor filed suit claiming breach of his employment contract and tenure agreement. The trial court granted summary judgment in favor of the university. The Supreme Court affirmed the decision of the trial court, holding (1) the professor's conduct constituted harassment under the terms of his employment contract such that the university could dismiss him; (2) the university did not deny the professor the procedural entitlements afforded under the professor's employment contract's terms; and (3) the university did not deprive the professor of due process. View "Haegert v. Univ. of Evansville" on Justia Law

In this case, a mother sought to relocate out-of-state with her child. The father filed a motion to modify custody and prevent the child's relocation. After an evidentiary hearing, which was conducted over two days with ten witnesses testifying, the trial court ruled in the father's favor. The court of appeals reversed. The Supreme Court granted transfer and reiterated that in family law matters, trial courts are afforded considerable deference. The Court then affirmed, holding that the trial court's judgment was well supported by the findings, and neither the judgment nor the findings were clearly erroneous. View "D.C. v. J.A.C." on Justia Law

After David Lawler obtained a civil judgment against Michael Kucholick's girlfriend for unpaid rent, Kucholick drove by Lawler's rural home and fired two shots into the home. Kucholick was found guilty of criminal recklessness and criminal mischief. The trial court sentenced Kucholick to an enhanced term of seven years for criminal recklessness and six months for criminal mischief, to be served concurrently. Kucholick appealed, arguing in part that his sentence was inappropriate in light of the nature of the offense and the character of the offender. The court of appeals concluded that Kucholick had met his burden of establishing that his sentence was inappropriate. The Supreme Court agreed and held that a modest sentence revision was warranted in this case. The Court then directed revision of Kucholick's aggregate sentence to an advisory term of four years, all executed. View "Kucholick v. State" on Justia Law

The State charged Defendant with four counts of drunk driving. Defendant moved to suppress the results of two breath tests, which the trial court granted. Rather than prosecute Defendant without the breath test evidence, the State dismissed the charges against him. Three days later, the State filed a notice of appeal, arguing that the trial court erred when it suppressed the breath test evidence. In response, Defendant argued that the court of appeals lacked jurisdiction to hear the State's appeal because it was untimely and not authorized by statute. The court agreed and dismissed the State's appeal. The Supreme Court vacated the opinion of the court of appeals and held that the appeal was timely and authorized by statute. Remanded for consideration of the merits of the State's appeal. View "State v. Holtsclaw" on Justia Law

Husband was found guilty of domestic battery and sentenced to two years in prison for shoving Wife and poking her in the forehead repeatedly, causing her pain. The court of appeals reversed the conviction, holding (1) in order for Wife to have suffered "bodily injury" sufficient to justify Husband's conviction, her pain "must be sufficient to rise to a level of 'impairment of physical condition'"; and (2) Wife's testimony was insufficient evidence of this requirement. The Supreme Court granted transfer, thereby vacating the court of appeals, and affirmed the conviction, holding (1) Wife's testimony was sufficient to sustain Husband's conviction, as under Court precedent, any physical pain is enough to constitute bodily injury; and (2) Husband's two-year sentence was appropriate. View "Bailey v. State" on Justia Law