Justia Indiana Supreme Court Opinion Summaries

Thirteen-year old D.M. and his friend were arrested after breaking in to a residence and taking several items of personal property. According to his mother, while D.M. was being held in a police cruiser he was prevented from speaking to his mother by police officers. Later D.M. and his mother signed a juvenile waiver acknowledging they understood D.M.'s rights. D.M. then confessed to a detective. The juvenile court found D.M. to be a delinquent child for committing acts that would have been felonies if they had been committed by an adult and placed D.M. on probation. D.M. appealed, arguing that he had not been given an opportunity for meaningful consultation with his mother and that the waiver of his rights was not knowing and voluntary. The court of appeals affirmed, and the Supreme Court granted transfer. The Court held (1) the police provided D.M. an opportunity for meaningful consultation with his custodial parent before the waiver of his rights, and (2) there is substantial evidence of probative value that D.M.'s rights were waived voluntarily and therefore the court did not err in admitting D.M.'s confession. View "D.M. v. State" on Justia Law

After sustaining serious injuries from an attack by a rottweiler, six-year-old Shawn Davis, through his mother as his next friend, filed a complaint against defendants Animal Control and the City of Evansville for failing to protect Davis from the attack. The trial court granted defendants' motion for summary judgment, finding that defendants were entitled to law enforcement immunity under the Indiana Tort Claims Act (ITCA). The court of appeals reversed, and defendants sought transfer. At issue was whether defendants were enforcing a law under the ITCA or rather failing to follow their own procedures for determining whether an animal is dangerous. The Supreme Court held that the alleged failure of defendants to follow their procedures constituted at worst a failure to enforce a law, for which defendants were immune from liability under the ITCA. Judgment of the trial court affirmed. View "Davis ex rel. Davis v. Animal Control" on Justia Law

Plaintiffs Michael Ashby and Randy O'Brien, inmates at the state department of correction, asserted professional malpractice complaints against attorney C. Bruce Davidson to The Bar Plan Mutual Insurance Company, Davidson's professional liability carrier. Bar Plan then intervened in consolidated actions for damages filed on behalf of plaintiffs against Davidson, asserting a cross-claim that it was not obligated to indemnify Davidson for the claims of plaintiffs because Davidson had failed to notify Bar Plan of any claims against him pursuant to Bar Plan's policy. The trial court granted summary judgment to Bar Plan. The Supreme Court held that Davidson's failure to comply with Bar Plan's policy was not dispositive because plaintiffs opposed summary judgment on grounds of waiver and estoppel. The Court then reversed summary judgment, holding that genuine issues of fact remained regarding whether Bar Plan's misrepresentation of valid coverage resulted in plaintiffs sustaining actual detriment. Remanded. View "Ashby v. The Bar Plan Mutual Insurance Co." on Justia Law

In 2008, Douglas Denzell was charged with resisting law enforcement and public intoxication. The trial court found Denzell incompetent to stand trial and committed him to the Division of Mental Health and Addiction for treatment. In 2009, after psychiatric evaluation reports revealed Denzell could be restored to competency, the trial court entered a commitment order. Denzell filed a motion to dismiss the charges. The trial court denied the motion. The court of appeals affirmed, finding the pending charges did not violate Denzell's right to due process on fundamental-fairness grounds because, under State v. Davis, there was no determination that Denzell would never be restored to competency. The Supreme Court affirmed, holding the appellate court was correct in rejecting Denzell's due process argument. The Court noted, however, that the standard the lower court used in evaluating Denzell's claim was too stringent. Although relevant precedent is a necessary consideration when evaluating defendants' fundamental-fairness claims, there may be factual scenarios that differ from Davis and other relevant precedent that still fall within the parameters of a due process violation. View "Denzell v. State" on Justia Law

Alva Curtis, a fifty-nine year-old man with a developmental disability, was arrested and charged with residential entry, battery, and criminal mischief. The trial court denied Curtis's motion to dismiss. The court of appeals reversed, finding the pending criminal charges violated Curtis's right to due process. The Supreme Court reversed and remanded, holding Curtis was entitled to dismissal under Indiana Criminal Rule 4(C), which provides that a defendant may not be held to answer a criminal charge for greater than one year, because the days that count toward Rule 4(C) in this case exceeded 365. The Court also held (1) that Curtis waived his constitutional speedy-trial claims because he failed to raised the claims for the first time on appeal, and (2) Curtis did not have a valid due process claim on fundamental-fairness grounds where, under State v. Davis, the trial court had not involuntarily committed the defendant or made an appropriate finding that Curtis will never be restored to competency. View "Curtis v. State" on Justia Law

Johnson, the defendant in this criminal case, wrote the trial court judge a few months prior to trial complaining that his public defender, who had a history of neglecting clients, had been neglecting his case. The judge forwarded the complaint to the public defender's office and took no further action. Johnson appealed, arguing that the judge's failure to inquire further into his complaint violated his Sixth Amendment right to the effective assistance of counsel. The court of appeals found that the trial court handled Johnson's complaint reasonably. The Supreme Court affirmed the defendant's conviction, but held that the trial court had a duty to receive assurances from the public defender's office that Johnson's complaint had been addressed. The trial court judge's failure, however, (1) did not violate Johnson's right to the effective assistance of counsel, and (2) did not prejudice the defendant because Johnson failed to renew his objection at trial and because defense counsel appeared at trial and subjected the state's case to meaningful adversarial testing. View "Johnson v. State" on Justia Law

In district court, appellant was convicted of one count of Class A felony child molestation based on penetration and one count of Class C felony child molestation based on fondling. The Court of Appeals reversed appellantâs Class C felony conviction because the charge was filed well after the applicable five-year statute of limitations. At issue was whether, under Ind. Code 35-41-4-2, the statute of limitations was tolled when appellantâs coercive authority over the victim ceased in 1991 or when the victim disclosed the abuse to the authorities in 2008. The Supreme Court reversed, holding that once concealment of evidence by the defendant has been established, statutes of limitations for criminal offenses are tolled under the statute until a prosecuting authority becomes aware or should have become aware of sufficient evidence to charge a defendant. The Court also held that there was no double jeopardy violation because each challenged offense was established by separate and distinct facts.

In September 1997, the State charged Defendant Charles Boyle with felony and misdemeanor motor vehicle violations. Defendant pled guilty to the felony "operation of a motor vehicle while a habitual traffic offender" charge against him. The trial court accepted the plea, and entered its judgment of conviction. Several years after the case had concluded, Defendant petitioned for post-conviction relief, and the trial court modified his conviction. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that the trial court lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

In August 2000, Defendant Jeffrey Brunner entered a guilty plea to "operating while intoxicated" (OWI). At the time of his plea, Defendant had an OWI within the previous five years that made the August, 2000 offense a felony. When going over Defendant's constitutional rights at trial, the court said "it [was] theoretically possible that a person found guilty of a . . . felony can have judgment of conviction entered and be sentenced as if it were a. . . misdemeanor." Defendant moved the court to modify its order of conviction to reduce the felony to a misdemeanor. The court granted the motion to modify, and the State appealed. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that trial court indeed lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

Defendant Tyrus Coleman shot Anthony Dye and Jermaine Jackson during a confrontation on Defendantâs property. The State charged Defendant with murder and attempted murder. At trial, Defendant testified and admitted to the shootings, but maintained that he shot in self-defense. Defendant was acquitted on the murder charge, but a mistrial was entered on the attempted murder charge. Before he could be retried, Defendant filed a motion to dismiss the attempted murder charge arguing that the State was âcollaterally estoppedâ from bringing the same case against him, and that if allowed to proceed, the second trial would constitute double jeopardy. The trial court denied that motion, and a retrial was held. The second jury found Defendant guilty as charged. The trial court sentenced Defendant to forty-five yearsâ imprisonment. A divided appellate court reversed Defendantâs conviction on collateral estoppel grounds. The Supreme Court held that collateral estoppel and double jeopardy did not preclude the State from retrying Defendant after a mistrial had been declared. The Court reversed the appellate courtâs decision, and affirmed the trial courtâs judgment.