Justia Civil Rights Opinion Summaries

This case before the Indiana Supreme Court involved the intersection of a successful Section 1983 federal action and Indiana’s public-employee indemnification statute. The plaintiff, Kailee Leonard, hit and killed a dog belonging to a state conservation officer, Scott Johnson. In response, Officer Johnson pursued misdemeanor charges against Leonard for leaving the scene of the accident. Leonard was subsequently charged but never arrested, and the charges were later dropped at Officer Johnson's request. Leonard then filed a federal lawsuit against Officer Johnson, claiming false arrest. The jury found in Leonard's favor, awarding her $10,000 in damages and $52,462 in attorney’s fees and costs. Unable to pay the full amount, Officer Johnson assigned his indemnification rights against the State to Leonard and her attorney. Leonard subsequently sued the State for a declaratory judgment that the State had a duty to indemnify Officer Johnson and pay the judgment. The trial court found in Leonard's favor, but the State appealed, arguing that Officer Johnson's actions constituted a criminal act.The Indiana Supreme Court held that Leonard had shown that Officer Johnson’s conduct was noncriminal, and the State did not rebut that showing. The Court clarified that a party seeking indemnification under the Indiana public-employee indemnification statute must initially show that the loss occurred because of a noncriminal act or omission. The burden then shifts to the State to rebut that showing by producing evidence establishing a prima facie case of criminal conduct. In this case, Leonard met her burden of producing evidence that Officer Johnson’s conduct was noncriminal, and the State failed to establish a prima facie case that he had committed the crime of false informing. Therefore, the court affirmed the trial court's decision ordering the State to indemnify Officer Johnson and pay the federal judgment. View "State v. Smith" on Justia Law

Edward Zaragoza, an inmate suffering from hypothyroidism, filed a lawsuit against three prison physicians and their employer. Zaragoza claimed that the doctors' treatment decisions, specifically their refusal to provide alternative medication despite the severe side effects he experienced from the prescribed medication, amounted to medical malpractice and deliberate indifference to his serious medical needs. The Indiana Supreme Court found that Zaragoza's expert's affidavit, which challenged the doctors' treatment decisions, was both admissible and substantively sufficient to create an issue of fact in the malpractice case. The court also found that there were disputes over whether the doctors knowingly failed to offer Zaragoza a potentially safer alternative medication. Thus, the court ruled that summary judgment was not warranted and reversed the trial court's decision, allowing Zaragoza's claims to proceed to trial. The court emphasized that summary judgment is not a summary trial and that genuine issues of material fact remained to be determined by a factfinder after a trial. View "Zaragoza v. Wexford of Indiana, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this action seeking to confiscate money under Indiana's civil forfeiture statute, holding that the right to a jury trial applies in such an action.The State filed a complaint to forfeit $2,435 in cash that police officers recovered after stopping Alucious Kizer for a traffic violation, alleging that the money had been "furnished or intended to be furnished" in exchange for a crime, that it had been "used to facilitate" a crime, or that it was "traceable as proceeds" of a crime. Kizer requested a jury trial. The State moved to strike the demand, arguing that no such right existed under either the Indiana or United States Constitution. The court of appeals reversed, concluding that Kizer was not entitled to trial by jury. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court, holding (1) Ind. Const. Art. I, 20 protects the right to a jury trial for in rem civil forfeitures; and (2) therefore, Kizer had a constitutional right to trial by jury. View "State v. $2,435 in U.S. Currency" on Justia Law

The Supreme Court dismissed Defendant's appeal of the sentence imposed in connection with his plea of guilty to four theft-related charges, holding that Defendant's written plea agreement with the State, which both he and his attorney signed, unambiguously waived his right to appeal his sentence.In exchange for a more lenient sentence, Defendant agreed to plead guilty to four theft-related charges and waive his right to appeal his conviction and sentence. The trial court accepted Defendant's plea and sentenced him to four years for burglary and thirty months for theft, ordering the sentences to run concurrently. Defendant appealed, but the court of appeals dismissed the appeals with prejudice. The Supreme Court affirmed, holding that this Court could not nullify Defendant's appeal waiver through direct appeal based on the claim that the waiver was not knowing and voluntary, but Defendant could still seek relief through post-conviction proceedings. View "Davis v. State" on Justia Law

The Supreme Court vacated a preliminary injunction granted by the trial court preliminarily enjoining the State from enforcing Senate Bill 1, which broadly prohibits abortion but makes exceptions in three circumstances, holding that Plaintiffs could not show a reasonable likelihood of success on their facial challenge.Plaintiffs, several abortion providers, brought this lawsuit seeking to invalidate Senate Bill 1 on the grounds that the law materially burdened a woman's exercise of her right to "liberty" under Ind. Const. Art. I, 1. The trial court agreed and granted the preliminary injunction. The Supreme Court reversed, holding (1) Plaintiffs had standing to contest the constitutionality of Senate Bill 1; (2) Senate Bill 1 was judicially enforceable; (3) Article 1, Section 1 protects a woman's right to an abortion that the extent that it is necessary to protect her life or to protect her from a serious health risk, but, otherwise, the General Assembly retains legislative discretion in determining the extent to which prohibit abortions; and (4) the record in this case did not support a preliminary injunction. View "Members of the Medical Licensing Bd. v. Planned Parenthood Great Northwest, Hawai'i, Alaska, Indiana, Kentucky, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions for murder and two counts of attempted murder, holding that the jury permissibly resolved the issues of fact raised on appeal against Defendant.On appeal, Defendant argued that the evidence did not support his convictions because the jury could not have found beyond a reasonable doubt that he was the shooter at issue. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to identify Defendant as the shooter; (2) the doubts Defendant raised about the evidence presented factual disputes that the jury was entitled to resolve; and (3) the jury could reasonably have resolved an inconsistency in the evidence in the State's favor. View "Young v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing this action under Indiana Trial Rule 12(B)(6) but modified the judgment to reflect that the dismissal was without prejudice, holding that the church-autonomy doctrine applied in this case and required its dismissal under Rule 12(B)(6).Plaintiff sued the Roman Catholic Archdiocese of Indianapolis, Inc., asserting intentional interference with his contract and employment with Cathedral High School. The Archdiocese moved to the dismiss the complaint and invoked three defenses under the First Amendment, including the church-autonomy defense. The trial court dismissed the case with prejudice for failure to state a claim and for lack of subject-matter jurisdiction. The Supreme Court affirmed, holding that dismissal under Rule 12(B)(1) was improper but that the church-autonomy doctrine barred Plaintiff's claims. View "Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis, Inc." on Justia Law

The Supreme Court reversed Defendant's convictions for several drug-related offenses, holding that the trial court abused its discretion by admitting evidence obtained during a search of Defendant's home.Officer Cody Scott was investigating a robbery when he detained Defendant for an outstanding warrant for his arrest. The officer asked Defendant if he would escort him inside the house, and Defendant agreed to the request. After Officer Scott observed possible narcotics in the residence he obtained a search warrant, the execution of which revealed various drug paraphernalia. The court of appeals affirmed Defendant's convictions, holding that the trial court did not abuse its discretion by denying Defendant's motion to suppress. The Supreme Court reversed, holding that Defendant's protections under Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), were violated in this case, and therefore, the trial court abused its discretion by admitting evidence obtained during the search. View "McCoy v. State" on Justia Law

The Supreme Court reversed the the order of the trial court granting summary judgment in favor of the Gary Housing Authority and dismissing allegations that the Housing Authority's notice of its administrative taking of 624 Broadway, LLC's property was constitutionally deficient, holding that the deficient notice was not harmless.The Housing Authority only provided notice of its taking of 624 Broadway's property by publication, despite knowing how to contact the LLC. After 624 Broadway unsuccessfully requested the Housing Authority to postpone the meeting to its appraiser could assess the property 624 Broadway brought this complaint, alleging that the Housing Authority violated its federal due process rights. The trial court granted summary judgment for the Housing Authority. The Supreme Court reversed, holding (1) the Housing Authority's constitutionally deficient notice to 624 Broadway was prejudicial; and (2) 624 Broadway was entitled to a damages hearing. View "624 Broadway, LLC v. Gary Housing Authority" on Justia Law

The Supreme Court affirmed Defendant's convictions of six offenses, including unlawful possession of a firearm by a serious violent felon in violation of Ind. Code 35-50-2-8, holding that none of Defendant's allegations of error required reversal.On appeal, Defendant argued that the trial court erred in giving Preliminary Instruction 18, and that the error was fundamental. The court of appeals agreed and reversed. The Supreme Court granted transfer and affirmed, holding (1) Defendant invited any error that arose from Preliminary Instruction 18, which precluded relief on direct appeal; (2) the traffic stop leading to Defendant's arrest did not violate the Fourth Amendment; and (3) Defendant waived his last allegation of error. View "Miller v. State" on Justia Law