Justia Indiana Supreme Court Opinion Summaries

A jury found Richard Barnes guilty of battery on a police officer and resisting arrest. The Supreme Court affirmed Barnes's conviction. Subsequently, Barnes petitioned for rehearing, which the Supreme Court granted. At issue in the appeal was whether the trial court erred when it refused to instruct the jury that Barnes, a suspected spouse abuser, had the right to get physical with the police officers if he believed their attempt to enter his residence was legally unjustified. The Court continued to affirm Barnes's conviction, holding that the Castle Doctrine, which authorizes a person to use reasonable force against another person to prevent the unlawful entry of his dwelling, is not a defense to the crime of battery or other violent acts on a police officer. View "Barnes v. State" on Justia Law

After decedent Mary Avery died, sons Rod and Marshall Avery filed a petition to remove daughter Trina Avery as the personal representative of decedent's estate and to probate decedent's 2008 will naming Rod as the personal representative. Trina filed a separate action to contest the 2008 will, asserting that it was the product of undue influence, fraud, and duress, and that decedent had executed a subsequent will in 2009 that superceded and revoked the 2008 will. When Defendants Rod and Marshall failed to file an answer or other responsive pleading, the trial court entered judgment by default against them. At issue on appeal was whether Defendants were required to file an answer in the will contest action when the statutory provisions did not explicitly mandate the filing of an answer. The Supreme Court affirmed, holding (1) the Indiana Rules of Trial Procedure require the timely filing of an answer or responsive pleading and do not exempt will contest actions from the requirement, and (2) by failing to file a timely answer or other proper response in the will contest, Defendants were subject to a default judgment. View "Avery v. Avery" on Justia Law

Loan borrowers entered into a residential mortgage loan. After a dispute about whether the borrowers paid the proper amount of property taxes, the mortgage holder filed a foreclosure action, alleging that the borrowers failed to pay monthly mortgage payments and fees. The borrowers asserted numerous legal defenses and claims against the mortgage holder and loan servicer. The borrowers asked for a jury trial on these defenses and claims, but the trial court denied the request, reasoning that foreclosure was an "essentially equitable" cause of action. The court of appeals reversed, concluding that the essential features of this case were not equitable. The Supreme Court affirmed the trial court's denial of the borrowers' request for a jury trial, holding that the borrowers' claims and defenses shall be tried in equity because the core legal questions presented by the borrowers' defenses and claims were significantly intertwined with the subject matter of the foreclosure action. View "Lucas v. U.S. Bank, N.A." on Justia Law

Jacob Gordon's mother sued Howard Community Hospital, alleging it committed medical malpractice while caring for her newborn son. In another count of the complaint, the mother sought separate damages for spoliation, alleging that the hospital had lost certain medical records associated with Gordon's care and that this loss made it impossible for Gordon to pursue a medical malpractice claim against one of his doctors, who was also a defendant. The trial court granted the Gordons partial summary judgment with respect to the third-party spoliation claim. The court of appeals affirmed. The Supreme Court vacated the opinion of the court of appeals and reversed the grant of partial summary judgment, holding that because the Court had so far declined to recognize a count alleging spoliation as representing a separate cause of action, the hospital was entitled to summary judgment on that claim. Remanded. View "Howard Reg'l Health Sys. v. Gordon" on Justia Law

Glenn Carpenter was discovered passed out in the waiting room of a dental office. Police officers aroused Carpenter and handcuffed him. When searching Carpenter the officers found a handgun with an empty magazine, marijuana, cocaine, and a crack pipe. Carpenter was convicted for unlawful possession of a firearm by a serious violent felon and being a habitual offender. The trial court imposed a twenty-year sentence for the felony conviction and added twenty years for the habitual finding. On appeal, Carpenter challenged the appropriateness of his sentence. The Supreme Court affirmed Carpenter's conviction but reversed the sentence, holding that a forty-year sentence was inappropriate taking into account the adverse character of the offender and the unaggravated nature of the offense as a whole. Remanded with instructions to issue an amended sentence of twenty years, ten years for the felony and ten for the habitual. View "Carpenter v. State" on Justia Law

Defendant Cedric Lewis was pulled over for speeding and arrested when the police officer discovered Lewis's driver's license had been suspended. After ordering Lewis out of the vehicle, the officer stuck his head inside the car to tell a passenger to get out and immediately saw a handgun near the driver's seat. Lewis moved to suppress the gun, arguing that the officer violated the Fourth Amendment by sticking his head into the car to search for weapons. The trial court overruled Lewis's objection and found him guilty of unlawful possession of a firearm by a serious violent felon. The court sentenced Lewis to twelve years in prison. The Supreme Court affirmed the judgment of the trial court, holding (1) the officer's discovery of the gun was not an impermissible search, and (2) the trial court' sentence, just two years above the advisory, was not inappropriate. View "Lewis v. State" on Justia Law

Following the death of his mother, Jeffery McCabe asserted a medical malpractice claim against his mother's medical care providers, who agreed to a settlement sufficient to allow McCabe to petition Indiana Patient's Compensation Fund for additional compensation. McCabe then filed an action pursuant to the Adult Wrongful Death Statute (AWDS), seeking additional recovery from the Fund for, inter alia, medical expenses and attorney fees. The trial granted granted partial summary judgment to the Fund, finding that the AWDS does not allow recovery of attorney fees. The court of appeals affirmed. The Supreme Court reversed the entry of partial summary judgment, holding that reasonable attorney fees incurred in the prosecution of an action under the AWDS are within the damages permitted by the statute. Remanded. View "McCabe v. Comm'r, Ind. Dep't of Ins." on Justia Law

Defendant Hematology-Oncology of Indiana, a health care provider, appealed a trial court judgment awarding attorney fees and litigation expenses brought under the Adult Wrongful Death Statute (AWDS) and the Medical Malpractice Act (MMA). The trial court entered judgment against defendants for $108,509 in attorney fees and litigation expenses in addition to a $229,148 judgment on the jury verdict for damages exclusive of attorney fees and expenses. The Court of Appeals affirmed. The Supreme Court granted transfer, holding (1) the trial court's award of attorney and litigation expenses was authorized by the AWDS; and (2) the total judgment, including both the jury's damage verdict and the attorney fees and expenses, exceeded the cap limiting damages against individual providers under the MMA. The Court affirmed in part and remanded to limit the provider's aggregate liability to the $250,000 cap prescribed by the MMA. View "Hematology-Oncology of Ind., P.C. v. Fruits" on Justia Law

Defendant Arturo Garcia-Torres was convicted of rape, attempted rape, and two counts of burglary and was sentenced to thirty-six years in prison. Defendant challenged the use of DNA evidence gathered when police obtained a cheek swab while Defendant was in custody after the attempted rape, arguing it was an invalid search under the Fourth Amendment. The Supreme Court affirmed, concluding (1) the cheek swab was a search requiring its own separate probable cause proceedings; (2) the cheek swab was taken under a valid consent; and (3) a Pirtle warning requiring the presence and advice of counsel prior to consenting to a search was not required. View "Garcia-Torres v. State" on Justia Law

Steven and Lauren Siwinski, homeowners in the town of Ogden Dunes, rented their home despite receiving a cease and desist letter advising them that that rentals were prohibited by the town zoning ordinances. The town filed suit against the Siwinskis for violating town ordinances. Both parties moved for summary judgment, and the trial court granted the town's motion for summary judgment and injunctive relief. The trial court entered judgment in favor of the town in the amount of $40,000. The court of appeals reversed and remanded with instructions that the trial court enter summary judgment in favor of the Siwinskis. On transfer, the Supreme Court affirmed the trial court's granting of summary judgment in favor of the town, holding that the Siwinskis impermissibly rented their dwelling in violation of the town's ordinances. The Court then held that the fine for violating this ordinance should not have exceeded $32,500. Remanded. View "Siwinski v. Town of Ogden Dunes" on Justia Law