Justia Constitutional Law Opinion Summaries

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 agreed with Plaintiffs in this declaratory judgment action, holding that Ind. Code 3-9-2-3 to -6 prohibits or otherwise limits corporate contributions to political action committees (PACs) or other entities that engage in independent campaign-related expenditures.Plaintiffs filed suit against several state officials responsible for enforcing Indiana's election laws, arguing that Ind. Code 3-9-2-4 and 3-9-2-5 were unconstitutional as applied. The district court dismissed the lawsuit for lack of standing, concluding that Plaintiffs had not suffered an injury. The United States Court of Appeals for the Seventh Circuit certified to the Supreme Court the question of whether sections 3-9-2-3 to -6 prohibit corporate contributions to Super PACs like the fund at issue. The Court of Appeals answered by holding that sections 3-9-2-3 to -6 prohibit corporate contributions to PACs earmarked for independent campaign-related expenditures. View "Indiana Right to Life Victory Fund v. Morales" 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 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 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 dismissed this action in which Plaintiffs challenged the City of Gary's local ordinance designed to protect the rights of immigrants, holding that Plaintiffs lacked standing to bring this action.Plaintiffs, four Indiana residents, challenged the "welcoming ordinance" adopted by Gary in 2017 establishing its commitment to protecting the rights of immigrants, seeking a declaration that four sections of the ordinance violated Ind. Code 5-2-18.2 and enjoining the city from enforcing those sections. The trial court entered summary judgment for Plaintiffs. The Supreme Court remanded the case to the trial court with instructions to dismiss the action for lack of standing, holding that where Plaintiffs alleged no injury but instead argued that neither statutory nor public standing requires an injury, Plaintiffs did not meet constitutional requirements for conferring standing. View "City Of Gary v. Nicholson" on Justia Law