Justia Indiana Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the juvenile court denying Appellant's request for relief under Trial Rule 60(B)(6), holding that the new jurisdictional rule announced in K.C.G. v. State, 156 N.E.3d 1281 (Ind. 2020), does not apply retroactively in a collateral attack to render a final delinquency adjudication void.Prior to 2021, the Juvenile Code defined a "delinquent act" only as an act committed by a child "that would be an offense if committed by an adult." In K.C.G., the Supreme Court concluded that Ind. Code 35-47-10-5 (the dangerous-possession-of-a-firearm statute) expressly applied only to child and thus could never be committed by an adult. At issue in this case was whether the jurisdictional rule announced in K.C.G. applies retroactively to collaterally attack a final delinquency adjudication as void. The Supreme Court affirmed the judgment of the juvenile court in this case denying the relief sought by Appellant under Trial Rule 60(B)(6), holding that this Court's K.C.G. decision does not apply retroactively. View "M.H. v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting a motion to compel arbitration brought by Defendant Star Financial Group, Inc. in this class-action complaint alleging that Defendant collected improper overdraft fees, holding that Plaintiffs' account agreement did not allow Defendant to add an addendum to the terms and conditions of the account agreement.When Plaintiffs opened their checking account they assented to an account agreement detailing the terms and conditions of their relationship with Defendant. Before Plaintiffs brought this suit Defendant added an arbitration and no-class-action addendum to the terms and conditions of Plaintiffs' account agreement. When Plaintiffs filed this lawsuit Defendants cited the addendum and filed a motion to compel arbitration. The trial court granted the motion. The Supreme Court reversed, holding that Plaintiffs were not bound by the arbitration addendum to their account agreement because the account agreement's change-of-terms provision did not allow Plaintiff to add the addendum. View "Decker v. Star Financial Group Inc." on Justia Law

The Supreme Court vacated the order of the trial court concluding that a constitutional taking of Landowners' property occurred from government-induced flooding, holding that whether the flooding's interference was substantial enough to create a taking was a question left unresolved by the trial court's findings.In 2009, the Town of Linden and Montgomery County approved a drainage-improvement plan that called for a reconstruction project that included a drainage easement on Landowners' property. After completion of the project, portions of Landowners' property flooded after any heavy rainfall, encumbering their farming enterprise. Landowners sued the Town and County for inverse condemnation. After remand, the trial court concluded that the project amounted to a taking. The Supreme Court vacated the trial court's order, holding (1) the trial court properly analyzed the government-induced flooding as a permanent physical invasion; and (2) the statutory right of entry set forth in Ind. Code Ann. 36-9-27-33 does not exempt a county from liability for a takings claim. View "Town of Linden v. Birge" on Justia Law

The Supreme Court reversed the order of the trial court denying a motion for summary judgment brought by a contractor in this action seeking subrogation recovery and other relief, holding that the contractor was entitled to summary judgment.The company that had a sprinkler system installed and other commercial tenants in the building that was flooded when the sprinkler system malfunctioned incurred property damages. The company's insurer sued the contractor who performed the work on the sprinkler system for subrogation recovery, and the remaining commercial tenants sued the contractor to recover damages. The contractor filed a motion for summary judgment, which the trial court denied. The Supreme Court reversed, holding that the contractor, as a matter of law, owed no duty to the non-contract tenants. View "U.S. Automatic Sprinkler Corp. v. Erie Insurance Exchange" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's denial of Appellant's post-conviction petition for permission to file a belated notice of appeal, holding that the appeal should be allowed to proceed.In 1999, Appellant pleaded guilty to burglary, robbery, rape, and criminal confinement, all felonies. In 2021, Appellant filed a petition for post-conviction relief seeking to file a belated notice of appeal under Rule 2 and claiming that when he signed his guilty plea there was no advisement that he had the right to appeal his sentence and that he did not learn of his ability to appeal until that that year. The trial court denied the petition without holding an evidentiary hearing, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant was not at fault in failing to file a timely notice of appeal and was diligent in pursuing his belated notice of appeal. View "Leshore v. State" on Justia Law