Justia Indiana Supreme Court Opinion Summaries
Barnes v. Indiana
A jury convicted Appellant Richard Barnes of misdemeanor charges involving battery, disorderly conduct, and resisting arrest. Appellant contested his conviction by raising technical errors at trial, specifically that the trial court did not advise the jury of his right to reasonably resist what he considered the officersâ unlawful entry to his apartment on the day he was arrested. The Supreme Court reviewed the trial record, and found that there is no right to âreasonably resistâ an entry by police officers. Furthermore, the Court held that the evidence was sufficient to support Defendantâs conviction, and affirmed the lower courtâs decision.
Zoeller v. Aisin USA Manufacturing, Inc.
The Indiana Attorney General (AG) sought to recover a tax refund issued to Aisin USA Manufacturing, Inc. (Aisin) at the Superior Court. The AG appealed the courtâs decision in favor of Aisin, arguing that because it was a tax matter, the Superior Court did not have jurisdiction to hear matters that âarose underâ the state tax laws. Upon review, the Supreme Court held that the case could proceed in the Superior Court. The Court found that despite the AGâs characterization of the case, the refund was a result of accounting and clerical errors within the Department of Revenue that were wholly unrelated to any interpretation or application of tax law. The Court remanded the case for further proceedings in Superior Court.
Wilkins v. Indiana
Facing felony drugs and firearms charges, Appellant Damion Wilkins sought to suppress evidence obtained when police executed a search warrant of a home. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
Lacey v. Indiana
Facing felony drugs and firearms charges, Appellant Cornelius Lacey, Sr. sought to suppress evidence obtained when police executed a search warrant of a home he was in. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
City of Indianapolis v. Armour
The City of Indianapolis abandoned the âBarrett Lawâ method of financing sewer improvements in favor of a new system that imposes less of a financial burden on property owners. To ease the transition, the City discharged all outstanding Barnett Law assessments owing as of November 1, 2005, but did not give refunds to those property owners who had previously paid their Barrett Law assessments in full or in part. Plaintiffs Christine Armour and other property owners who had paid their Barrett Law assessments in full petitioned the City for refunds in the amount equal to the assessments discharged in 2005. In their claim, Plaintiffs alleged that the City had violated their federal constitutional rights to due process and equal protection under the Fourteenth Amendment. At trial, the court granted Plaintiffsâ motion for summary judgment, and the City appealed. On appeal, Plaintiffs abandoned their due process claim and sought to have the equal protection claim sustained. The appellate court affirmed the trial courtâs judgment. The City appealed again. Upon review, the Supreme Court held that the City did not violate the Equal Protection Clause of the Fourteenth Amendment because forgiving the outstanding assessment balances was rationally related to a legitimate governmental interest. The Court reversed the decision of the trial court and remanded the case for further proceedings.
Konopasek v. Indiana
In June, 2008, Appellant Joshua Konopasek attended a house party in Rochester. At some point, he got into an altercation with another party-goer. The evening ended with Appellant shoving the other party-goer to the ground and stomping on his head. Appellant would later be charged with battery causing serious injury. Appellant claimed self-defense. On direct examination, Appellantâs attorney elicited testimony from him regarding his probationary status. On cross-examination, the State inquired further about appellantâs probation. Defense counsel objected that the stateâs inquiry was irrelevant. The trial court overruled the objection. Petitioner was found guilty as charged, and sentenced to eight yearsâ imprisonment, with six suspended and credit for time served. On appeal, Petitioner argued that there was insufficient evidence to convict him of battery, and that the trial court abused its discretion by admitting the evidence elicited by the State on his probation. The appellate court affirmed the trial court. The Supreme Court agreed too, holding that the Stateâs elicited testimony on the length of Petitionerâs suspended sentence was relevant and admissible. Furthermore, the Court found the evidence sufficient to support his conviction. The Court affirmed the lower courtsâ decisions.
Serrano v. Indiana
Appellant Martin Serrano lost his truck in a forfeiture action based on the presence of cocaine residue found in the carpet of the vehicle, and on a box of quarters. Appellant challenged the sufficiency of the evidence, contending that the State failed to prove that the presence of cocaine in his truck was anything more than "incidental or fortuitous." The Court of Appeals agreed with Appellantâs argument. The Supreme Court found that though Appellant admitted he was a cocaine user, âthere are numerous ways that cocaine residue may have made its way into the truck that [did] not involve the use of the vehicle in furthering the possession of cocaine.â The Supreme Court affirmed the appellate courtâs decision.
Posted in:
Criminal Law, Indiana Supreme Court
Love v. Rehfus
Appellant-Plaintiff Bradley Love was a volunteer and part-time firefighter for the Sugar Creek Township Fire Department (Department) during the spring of 2006. During the Republican primary election that spring, Bob Boyer, a retired volunteer firefighter, challenged the incumbent, C.O. Montgomery, for the office of Sugar Creek Township Trustee. One of the Trusteeâs principal duties is to appoint a fire chief to oversee the Department. On April 24, 2006, a few weeks before the May 2nd primary, an email concerning Boyerâs political intentions was forwarded to Appellant by an acquaintance. Eventually a copy of Appellantâs email made its way to Appellee-Defendant Fire Chief Robert Rehfus. After consulting with Township counsel, Appellee sought to verify whether some of the facts in the email were true. Appellee was particularly offended by parts of the email. Concluding that Appellant made some false statements in the email, Appellee terminated Appellantâs employment for conduct unbecoming a firefighter and failing to be truthful in accordance with the Departmentâs General Orders. Appellant filed suit under 42 U.S.C. § 1983 in Hancock Circuit Court against both the Chief and the Township for violation of his constitutional rights under the First and Fourteenth Amendments. Appellees filed a motion for summary judgment arguing both that Appellantâs constitutional rights were not violated because false statements are not protected, and that the Township could not be held liable under § 1983 on a theory of respondeat superior. The trial court entered summary judgment on behalf of Appellees on both grounds. The appellate court reversed, finding that Appellantâs speech was protected under the First Amendment and that the Township was subject to liability under § 1983 because the Chief established final government policy respecting employment decisions within the fire department. The Supreme Court on review affirmed the appellate court decision, finding that the email was constitutionally protected speech, and that there were genuine issues of material fact that needed to be resolved in order to determine whether, as a matter of state law, the township is liable under 42 U.S.C. § 1983 for the Chiefâs actions.
Posted in:
Constitutional Law, Indiana Supreme Court
Janiec v. Lake Cty. Bd. of Election & Registration
Appellant George Janiec, a Republican Party candidate for Mayor of the City of Hammond and an incumbent member of the Hammond School Board, was removed from the May 3, 2011 primary election ballot by Appellee Lake County Board of Election and Registration. Appellant challenged the Boardâs decision in Lake Superior Court, requesting judicial review and injunctive relief. The trial court found in favor of the Board. Appellant appealed the trial courtâs decision and sought immediate transfer of the appeal to the Supreme Court. The Board and Lake Superior Court held that Appellantâs candidacy was inconsistent with the ethical policies applicable to members of the Hammond School Board. The Supreme Court found no basis in statute or law for disqualifying Appellant on this basis, and enjoined the Board from removing Appellantâs name from the ballot in the May 2011 primary election.
George v. Nat’l Collegiate Athletic Assoc.
The National Collegiate Athletic Association (NCAA) randomly allocated championship tickets to applicants who had offered to purchase tickets by submitting the face value of the tickets along with a non-refundable handling fee. The face-value amount (but not the handling fee) was refunded to applicants whose offers were not accepted. Plaintiffs in this case submitted offers to the NCAA to purchase tickets for the NCAA Division I men's basketball tournament, but their offers were not accepted. Dissatisfied with not being able to purchase tickets, the plaintiffs filed suit against the NCAA in federal court, alleging several claims, the underlying basis being that the NCAA's ticket-distribution system constituted an unlawful lottery under state law. The trial court dismissed the complaint for failure to state a claim, holding that even if the NCAA was operating an illegal lottery, plaintiffs' claims were barred by in pari delicto because they were willing participants in it. On appeal, the majority of the appellate panel held that the ticket-distribution process was a lottery, and the in pari delicto defense was not available because the NCAA had a greater degree of fault than the plaintiffs. The NCAA appealed the decision, and the same appellate panel vacated its prior decision. Pursuant to state appellate procedure, the panel presented certified questions for Supreme Court consideration, in particular, whether the NCAA's ticket distribution process was an unlawful lottery. The Court found that state law does not define "lottery," and following its holding in Tinder, defined the term as "a scheme for the distribution of prizes by lot or chance among those who provided ⦠consideration." The Court found that the NCAA distribution scheme does not fall within definition, and is not an unlawful lottery under state law.
Posted in:
Gaming Law, Indiana Supreme Court