Justia Indiana Supreme Court Opinion Summaries

This case involved a trial court's discretion in granting a mistrial. Defendant vacillated throughout the trial seeking to proceed pro se and at other times wanting court-appointed counsel. Ultimately, the relationship between Defendant and his counsel reached its low point when later in the trial Defendant testified. Defendant complained to the jury about his counsel's trial strategy, and his response to counsel risked a mistrial. The judge then instructed Defendant to stop speaking and directed the jury to be removed from the courtroom. Before the jury left the courtroom, the judge directed the bailiff to cover Defendant's mouth so he would stop talking. Defendant later completed his direct and cross-examinations without incident. Only after Defendant completed his testimony did defense counsel move for a mistrial. The trial court refused to grant a mistrial. The Supreme Court affirmed, holding that Defendant did not suffer actual harm from the bailiff restraining him, and therefore, the court did not abuse its discretion in denying the motion for mistrial. View "Vaughn v. State" on Justia Law

At issue in this case was the Indiana Guest Statute (Statute), which prevents certain designated passengers from recovering damages for injuries resulting in ordinary negligence of the motor vehicle operator, where such passenger was "being transported without payment in or upon the motor vehicle." Son was traveling as a passenger in a motor vehicle operated by Father. When they arrived at their destination, Son exited the vehicle and began motioning for Father to drive forward into a parking space. Father then accidentally pinned Son between his vehicle and the next vehicle, resulting in injuries to Son. Son and his wife brought a damage action alleging negligence by Father. The trial court granted summary judgment to Father, finding that the Statute was applicable to the facts. The court of appeals reversed. The Supreme Court granted transfer and reversed the trial court, holding that, as to injuries inflicted when a passenger has exited the vehicle and is standing outside of it and directing the driver's attempt to park, the passenger is not "in or upon" the vehicle and thus is not precluded from bringing a negligence action against the driver. View "Clark v. Clark" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit burglary and was adjudged to be a habitual offender. Defendant subsequently filed a petition for post-conviction relief, alleging prosecutorial misconduct and ineffective assistance of trial counsel. The trial judge granted Defendant's petition, reversed his conviction, and ordered a new trial. The court of appeals reversed. The Supreme Court granted transfer and affirmed the judgment of the post-conviction court, holding that the post-conviction court did not err in concluding that Defendant was entitled to a new trial because of the ineffective assistance of trial counsel and because of prosecutorial misconduct. View "State v. Hollin" on Justia Law

After a trial before a commissioner, Defendant was convicted for misdemeanor criminal trespass after Defendant refused to leave a bank upon the request of the bank's manager and a police officer. Defendant appealed, contending that there was insufficient evidence to support any inference that he lacked a contractual interest in the property upon which he was accused of trespassing. The court of appeals reversed and vacated the conviction. The Supreme Court granted transfer and affirmed Defendant's conviction, holding that there was sufficient evidence from which a reasonable jury could infer that Defendant did not have a contractual interest in the bank's real property. View "Lyles v. State" on Justia Law

In this case, after two hearings, the trial court issued a number of post-dissolution orders. Relevant to this appeal were the trial court's specific findings related to the emancipation of a child and the requirement of a parent to contribute toward the child's post-secondary educational expenses. The court of appeals (1) reversed on the issue of emancipation, determining that the trial court clearly erred in concluded that the child was emancipated as of a certain date under Ind. Code 31-16-6-6(a); and (2) reversed the trial court's finding that Father was not responsible for educational expenses regarding the child after hearing testimony from Father, Mother, and the child. The Supreme Court (1) reversed the court of appeals on the emancipation issue and remanded to the trial court to determine the proper date of the child's emancipation; and (2) reversed the court of appeals and affirmed the trial court's ruling on post-secondary educational expenses. View "Hirsch v. Oliver" on Justia Law

Defendant Michael Sharp was convicted and sentenced for two counts of child molesting. The court of appeals rejected Sharp's several appellate claims and affirmed the trial court. Seeking transfer, Sharp asserted a single claim, that the court of appeals should have considered his credit restricted felon status when evaluating his request for appellate sentence review. The Supreme Court affirmed, rejecting the rationale applied by the court of appeals but reaching the same outcome regarding the appropriateness of Sharp's sentence, holding (1) appellate sentence review may take into consideration the potential consequences of an offender's status as a credit restricted felon; but (2) Sharp's sentence was appropriate. View "Sharp v. State" on Justia Law

Plaintiff claimed that her husband's death was caused by Defendant's negligence in installing or removing asbestos-containing materials and brought product-liability and contractor-negligence claims against Defendant. The trial court granted summary judgment in favor of Defendant, concluding (1) the application or removal of asbestos-containing products or asbestos-insulted equipment by a contractor is an improvement to real property, and (2) thus, the claim had not been brought within the time Indiana law requires for a claim arising from the construction of an improvement to real property. The Supreme Court reversed, holding that there was a genuine issue of material fact as to whether Defendant's work constituted an "improvement to real property," as that phase was commonly understood. View "Gill v. Evansville Sheet Metal Works, Inc." on Justia Law

This petition for post-conviction relief followed Defendant Roy Ward's second trial during which he pled guilty to the 2001 rape and murder of a fifteen-year-old. Ward was sentenced to death following a penalty-phase jury trial. The Supreme Court affirmed Ward's sentence on direct appeal. Ward subsequently sought to have his death sentence set aside by filing a petition for post-conviction relief, in which he raised a number of issues. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) any deficiencies in trial counsel's performance in their mitigation investigation and presentation did not prejudice Ward's defense; (2) trial counsel w343 not ineffective in failing to challenge certain aspects of the State's case; (3) appellate counsel rendered competent, constitutionally adequate representation; (4) trial counsel did not render ineffective assistance under U.S. v. Cronic; (5) Indiana's death penalty statute comports with the state and federal Constitutions; and (6) Ward's claim under Napue v. Illinois was waived. View "Ward v. State" on Justia Law

In this case the Supreme Court examined whether income received by a corporation's affiliated foreign reinsurance companies falls within the ambit of Indiana's gross premium privilege tax statute and is on that basis exempt from Indiana adjusted gross income tax. The corporation in this case was UPS, which protested the Indiana Department of Revenue's audit, which disallowed the exclusion from Indiana adjusted gross income the income of UPS's affiliates. The Indiana tax court granted UPS's motion for summary judgment, reasoning that because UPS was "subject to" the premium tax, it was exempt from the adjusted gross income tax. The Supreme Court reversed, holding that because the record did not establish that during the years in question UPS's affiliates were doing business within the state of Indiana, which was a necessary condition in order to be "subject to" the premium tax, UPS failed in its burden of establishing that it was entitled to summary judgment as a matter of law. Remanded. View "Ind. Dep't of Revenue v. UPS" on Justia Law

Defendant was charged with felony attempted murder. After a bench trial, the trial court rejected Defendant's insanity defense, finding that Defendant's behavior was the result of his voluntary abuse of alcohol. The trial court then found Berry guilty as charged. The court of appeals reversed, concluding that Defendant suffered from "settled insanity," a mental disease or defect caused by Defendant's prolonged and chronic abuse of alcohol, which rendered him unable to appreciate the wrongfulness of his conduct. The Supreme Court granted transfer and affirmed the trial court, holding (1) there was credible expert testimony that Defendant's behavior was caused by the voluntary abuse of alcohol and not a mental disease or defect as defined in Indiana's insanity statute; and (2) accordingly, under the applicable standard of review, the trial court properly rejected Defendant's insanity defense. View "Berry v. State" on Justia Law