Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court excluding certain testimony from the jury trial of Defendant's habitual offender status, holding that the trial court did not err by excluding the testimony.The trial court excluded Defendant's testimony to the circumstances of his "most serious crime of conviction," his intent to rehabilitate himself, and his purported innocence of one of his prior, unrelated felonies as irrelevant to the issue of whether Defendant had accumulated the requisite convictions. The Supreme Court affirmed, holding that Defendant's testimony was irrelevant because it did not tend to prove or disprove his convictions, and therefore, Defendant had no constitutional right to present the evidence. The Supreme Court affirmed, holding (1) Defendant's testimony was irrelevant because it did not tend to prove or disprove his convictions; and (2) Defendant had no constitutional right to present irrelevant evidence. View "Harris v. State" on Justia Law

The Supreme Court affirmed the summary judgment granted by the trial court in favor of a school corporation that contractually agreed to make biannual payments to a company for access to a wind turbine, holding that the contract was void and unenforceable.Randolph Eastern School Corporation (RESC) contractually agreed to make biannual payments to Performance Services, Inc. for a wind-turbine project. As part of the contract, Performance agreed to provide RESC with financial benefits tied to the net revenue of the turbine. RESC, which never made any payments to Performance, brought this declaratory judgment action seeking to void the contract on the grounds that it constituted an illegal investment. The trial court granted RESC's motion for summary judgment, concluding that the contract constituted an unauthorized investment. The Supreme Court affirmed, holding that the contract between RESC and Performance was void and unenforceable because it constituted an investment unauthorized by statute. View "Performance Services, Inc. v. Randolph Eastern School Corp." on Justia Law

The Supreme Court affirmed the order of the trial court suppressing incriminating statements Defendant made immediately following a polygraph examination, holding that before excluding evidence as a Trial Rule 37 discovery sanction, a trial court must find that the exclusion is the sole remedy available to avoid substantial prejudice and that the sanctioned party's culpability reflects an egregious discovery violation.Defendant was interviewed at the police department as part of an investigation as to whether he sexually abused a minor. Defendant agreed to sit for a polygraph and agreed that the results of the polygraph would be admissible if the State charged him with a crime. The State subsequently charged Defendant with child molesting. Defendant moved to suppress the polygraph results and his related statements, arguing that his statements were not voluntary or reliable. The trial court denied the motion. On the eve of trial, the deputy prosecutor disclosed that the officer who administrated the exams had unilaterally changed the exam to a "non-stipulated," inadmissible investigatory examination. The judge suppressed the incriminating statements as a discovery sanction. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court's order enforced Trial Rule 37 within the limits set forth in this opinion. View "State v. Lyons" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Father committed an act of domestic or family violence against Child and that he represented a credible threat to the family's safety and thus granting Mother's petition for an ex parte petition order, holding that the trial court's evidence-based findings supported its judgment.Specifically, the Supreme Court held (1) the evidence presented supported the trial court's finding that Father committed an act of domestic or family violence; and (2) Mother presented probative evidence to support the trial court's finding that Father posed a credible threat to Mother or Child's safety. View "S.D. v. G.D." on Justia Law

The Supreme Court affirmed the judgment of the trial court excluding the opinion testimony from three of Defendant's family members regarding the victim's untruthful character, holding that the trial court erred in excluding the opinion testimony but that the error was harmless.Defendant was charged with several felony child molestation counts and one count of felony incest for molesting his minor daughter. Before trial, Defendant requested to call three relatives as witnesses to testify about the opinion of the victim's character for untruthfulness. The trial court excluded the testimony on the grounds that Defendant had not established a proper foundation. After trial, the jury found Defendant guilty of felony child molesting. The Supreme Court affirmed, holding that the trial court erred in excluding the testimony of one witness for lack of foundation, but the error was harmless. View "Hayko v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing a Monroe County action with prejudice and denying Appellant's motions to correct error and to amend her complaint, holding that a plaintiff seeking tort damages from both government and non-government defendants must sue all such tortfeasors in one lawsuit.Plaintiff sustained injuries while driving in an I-69 construction zone. Plaintiff obtained a judgment against a non-government defendant in Lake County to satisfy the requirements for obtaining insurance coverage. After Plaintiff and the insurer settled her insurance claims Plaintiff again sued for the same injuries, this time in the Monroe Circuit Court against six other defendants, both government and non-government. The trial court dismissed the action with prejudice, concluding that collateral estoppel and claim splitting barred Plaintiff's claims. The Supreme Court affirmed, holding (1) the trial court was correct in dismissing Plaintiff's action on issue preclusion grounds; and (2) Plaintiff was not entitled to relief on her remaining claims of error. View "Davidson v. State" on Justia Law

The Supreme Court dismissed this appeal from a decision of the court of appeals requiring Adoptive Parents to provide notice to biological Father of the temporary custody of Child, rending the trial court's temporary custody order void for lack of personal jurisdiction, holding that this Court lacked appellate jurisdiction.After Child was placed full-time with Adoptive Parents, Adoptive Parents petitioned to adopt child and separately moved for temporary custody. Father was not served the petition or motions. After a hearing, the superior court granted Adoptive Parents temporary custody, determining that it was in Child's best interests while the adoption petition was pending. Father later filed a motion to set aside the order of custody on the grounds that he was not given notice. The trial court denied the motion. Adoptive Parents appealed. The Supreme Court dismissed the appeal, holding that the superior court's order granting temporary custody was not a final judgment because it neither disposed of all claims for all parties nor stated that there was no just reason for delay. View "P.L. v. A.H." on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, felony robbery resulting in serious bodily injury, and two counts of criminal confinement and his sentence of life without parole for the murder conviction, holding that Defendant was not entitled to relief on his allegations of error.Defendant, a gang leader, supervised and participated in the torture and brutal killing of member of the gang that other members believed was a police snitch. Once the victim was dead, Defendant oversaw cleaning up the crime scene and then hid the body. The Supreme Court affirmed the judgment in its entirety, holding (1) there was sufficient evidence both to find that Defendant was a "major participant" in the victim's murder and to support two of the statutory aggravators; (2) the trial court did not abuse its discretion in declining to instruct the jury as proposed by Defendant; and (3) the record supported the other aggravating factors not relating to the life without parole sentence. View "Owen v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of life imprisonment without the possibility of parole (LWOP) in connection with his conviction for the murder and burglary of his ex-girlfriend, holding that Defendant's LWOP sentence was not inappropriate.On appeal, Defendant argued that the jury failed to meet all statutory prerequisites for an LWOP sentence by failing to determine that the aggravating circumstances outweighed the mitigating circumstances and that his sentence was inappropriate in light of the mental illness he was suffering when he committed the crimes. The Supreme Court affirmed, holding (1) the jury's LWOP recommendation reflected its determination that the aggravating circumstances outweighed the mitigating circumstances; and (2) the LWOP sentence was not inappropriate. View "Oberhansley v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal of his sentence, holding that Appellant's written plea agreement with the State unambiguously waived his right to appeal his sentence.Appellant pled guilty to four theft-related offenses in exchange for a more lenient sentence. Both Appellant and his attorney signed a three-page plea agreement with the State in which Appellant waived his right to appeal his sentence. Appellant sought to appeal his sentence despite his plea agreement. The Supreme Court dismissed the appeal, holding (1) Appellant waived his right to appeal his sentence; and (2) if Appellant's guilty plea was not knowing and voluntary because the trial judge's misstatements misled him as to which rights he was waiving, Appellant's remedy was to vacate his conviction through post-conviction relief proceedings. View "Davis v. State" on Justia Law