Justia Indiana Supreme Court Opinion Summaries

Respondent, a judge of the city court, dismissed the traffic infraction cases of all litigants who attended traffic school and paid the applicable fee. Respondent also entered default judgment, imposed fines and court costs, and ordered the suspension of driver's licenses of all litigants who selected traffic school but failed to complete the class. Respondent, however, had no authority to discharge traffic infraction cases without a specific request from the prosecuting attorney or to divert litigants' cases through a de facto deferral program not authorized by the county prosecutor. The Indiana Commission on Judicial Qualifications then brought a judicial disciplinary action against Respondent. Respondent and the Commission agreed that by referring traffic infraction litigants to the traffic school and then dismissing their cases upon their completion of the program without any dismissal request from the prosecutor, Respondent abused his judicial authority, committed conduct prejudicial to the administration of justice, and violated the Code of Judicial Conduct's provisions that required him to comply with the law. As a sanction for this misconduct, the Supreme Court suspended Respondent from office without pay for a period of sixty days. View "In re Judge Harkin " on Justia Law

The Indiana Constitution authorizes the General Assembly to disenfranchise "any person convicted of an infamous crime." Plaintiff was convicted of misdemeanor battery. During his incarceration, Plaintiff was informed that his voter registration was canceled in accordance with several provisions of state law under which persons convicted of crimes and sentenced to imprisonment are disenfranchised for the duration of incarceration. After his release, Plaintiff filed a lawsuit seeking declaratory and injunctive relief against state and county election officials. The Supreme Court accepted certification to answer whether Plaintiff's constitutional rights were violated when his voter registration was canceled because, as Plaintiff alleged, misdemeanor battery was not an "infamous crime." The Court held (1) the crime in this case was not an "infamous crime," but (2) the General Assembly has separate constitutional authority to cancel the registration of any person incarcerated following conviction for the duration of the incarceration, and (3) therefore, Plaintiff's Constitutional rights were not violated when he was disenfranchised while incarcerated. View "Snyder v. King" on Justia Law

Following the death of their full-term baby daughter in utero during labor, Plaintiffs brought an action against the hospital, the Plaintiffs' nurse-midwife, and the nurse-midwife's alleged employer for negligent infliction of emotional distress. The trial court granted summary judgment to Defendants. The court of appeals reversed. The Supreme Court granted transfer and reversed the trial court, holding (1) Plaintiffs' claims were not precluded by the Indiana Child Wrongful Death Act; (2) Plaintiffs were not precluded from maintaining an action for emotional distress under the bystander rule; and (3) Plaintiffs' actions were not barred by the Indiana Medical Malpractice Act. Remanded. View "Spangler v. Bechtel" on Justia Law

Appellant was charged with tattooing a minor for taking his former Stepdaughter to get a tattoo. While the charge was pending, a detective arranged for Stepdaughter to make recorded phone calls to Appellant to obtain evidence concerning a sexual relationship Appellant allegedly forced upon Stepdaughter. The State subsequently charged Appellant with several sex-related crimes. Appellant moved to suppress the incriminating statements from the conversations, claiming they were obtained in violation of his right to counsel. The trial court denied the motion and convicted Appellant as charged. The court of appeals affirmed. At issue before the Supreme Court was whether an "inextricably intertwined" exception to the offense-specific nature of the right to counsel existed under the state Constitution. The Court affirmed, holding (1) under the Indiana Constitution, the right to counsel is violated only where the different offense is inextricably intertwined with the charge on which counsel is already representing the defendant; and (2) because there was no evidence that it would have been objectively foreseeable for the detective, at the time he conducted the phone calls, to believe the pending tattooing offense was inextricably intertwined with the alleged sexual misconduct, the recorded conversations did not violate Appellant's right to counsel. View "Jewell v. State" on Justia Law

Appellant pled guilty to driving while intoxicated after proceeding pro se in plea negotiations with the State. Appellant filed a petition for postconviction relief, alleging that his waiver of counsel was invalid. The trial court denied the petition. The Supreme Court granted transfer and announced that future defendants expressing a desire to proceed without counsel must be informed that an attorney is more experienced in plea negotiations and better able to identify and evaluate potential defenses and problems in the prosecution's case (Hopper warning). The Court subsequently granted the State's petition for rehearing and affirmed the post-conviction court, holding (1) the Sixth Amendment does not require the same warnings and analysis for a valid waiver of counsel during plea negotiations as it requires for the entry of a guilty plea; (2) the post-conviction court properly found that Hopper's waiver of counsel during his guilty plea hearing was voluntary and intelligent; and (3) the absence of the Hopper warning is not a per se violation of a defendant's right to counsel, but rather, courts should consider the absence of the instruction as an additional factor in a totality of the circumstances approach. View "Hopper v. State" on Justia Law

Washington Township and the West Central Conservancy District (WCCD) owned property within the Town of Avon's boundaries that overlay an underground aquifer. After the Township and WCCD began exploring the possibility of drilling wells into the aquifer in order to withdraw water and sell it to third parties, the Town passed an ordinance that (1) prohibited taking water from a watercourse for retail, wholesale, or mass distribution unless done on behalf of the Town, and (2) defined a watercourse as any body of water whether above or below ground. The Township and WCCD filed complaints challenging the ordinance's validity under the state's Home Rule Act. The trial court granted summary judgment for the Township and WCCD. The court of appeals affirmed. The Supreme Court reversed, holding (1) the aquifer at issue was a watercourse under Indiana law; (2) the Home Rule Act permitted the Town to regulate another political unit's attempt to withdraw water from the aquifer; and (3) the Town's proposed regulation was not preempted by statutes authorizing the Department of Natural Resources to regulate aquifers. View "Town of Avon v. W. Cent. Conservancy Dist." on Justia Law

A trial court found Lisa Gray guilty of possessing marijuana as a class A misdemeanor. The court of appeals set aside the conviction on the grounds of insufficient evidence. At issue on appeal was whether the trial court properly found Gray had constructive possession of the marijuana when it was found on the floor of her apartment and Gray's son testified that the marijuana belonged to him. The Supreme Court granted transfer, vacated the court of appeals, and affirmed the trial court, holding that there was substantial evidence of probative value from which the court could have found beyond a reasonable doubt that Gray committed the crime. View "Gray v. State" on Justia Law

Appellant Indiana Spine Group provided medical services to employees of various businesses for injuries the employees sustained arising out of and during the course of their employment. The employers authorized the services and made partial payments. In each case, more than two years after the last payments were made to the injured employee, Appellant filed with the worker's compensation board an application for adjustment of claim seeking the balance of payments. The Board dismissed the applications as untimely. In each case the court of appeals reversed and remanded. At issue on appeal was what limitation period was applicable to a medical provider's claim seeking payment of outstanding bills for authorized treatment to an employer's employee when the Worker's Compensation Act was silent on the question. The Supreme Court reversed the Board, holding (1) the limitation period contained in the general statute of limitation enumerated in Ind. Code 34-11-1-2 controlled; and (2) because Appellant's claim was timely under the statute, the Board erred by dismissing Appellant's application. View "Indiana Spine Gp., PC v. Pilot Travel Ctrs., LLC" on Justia Law

When he was fourteen years old, D.C. and three other boys broke into the home of an elderly woman, ransacked the home, and injured the homeowner. At a dispositional hearing, the juvenile court imposed on D.C. a determinate commitment of two years at the Department of Correction to be followed by an indeterminate commitment. D.C. appealed the dispositional order, arguing that the juvenile court incorrectly ordered both a determinate commitment and indeterminate commitment. The court of appeals agreed and reversed in part and remanded with instructions that the juvenile court impose a determinate commitment only. The Supreme Court granted transfer and reversed the trial court's dispositional order, holding that the determinate and indeterminate commitment statutes in question were unambiguously mutually exclusive, and thus the trial court could impose only one of the commitments on D.C. Remanded to the trial court to decide, in its discretion, which type of commitment was appropriate. View "D.C. v. State" on Justia Law

After a jury trial, Appellant Otha Hamilton was convicted of one count of molesting a child for an incident in which Appellant's nine-year-old step-granddaughter performed oral sex on him. Hamilton was sentenced to the maximum sentence of fifty years in prison. Hamilton appealed, arguing, inter alia, that the sentence was inappropriate given the nature of his offense and his character. The court of appeals affirmed the conviction and sentence. The Supreme Court affirmed Hamilton's conviction but revised his sentence, holding that, given the nature of Hamilton's sexual misconduct, the sentence imposed by the trial court was inappropriate. Remanded with instructions to enter an amended sentence of thirty-five years in prison. View "Hamilton v. State" on Justia Law