Justia Government & Administrative Law Opinion SummariesArticles Posted in Indiana Supreme Court
Ballard v. Lewis
The Indianapolis Marion County City-County Council and Mayor Gregory Ballard agreed on an ordinance dividing Marion County into legislative districts. Three members of the Council (“Plaintiffs”) filed a complaint seeking a declaration that the ordinance failed to comply with the Redistricting Statute for Marion County, which assigns the task of redrawing the County’s legislative districts to the judiciary if the County’s legislative and executive branches become deadlocked over required redistricting. The trial court granted Plaintiffs’ motion for partial summary judgment and then drew new legislative districts, concluding that because the Council divided the County by ordinance in 2011, not during 2012 as required by the Redistricting Statute, the ordinance failed to satisfy the requirement for “mandatory redistricting” during 2012. The Supreme Court reversed, holding that this case did not present a redistricting impasse that required judicial intervention. View "Ballard v. Lewis" on Justia Law
Alva Elec., Inc. v. Evansville-Vanderburgh Sch. Corp.
In order to renovate a former warehouse building into administrative offices, Evansville-Vanderburgh School Corporation (“School Corporation”) implemented a plan to convey the Building to the EVSC Foundation (“Foundation”), a private non-profit entity, have the Foundation contract with a contractor for the renovations, and then have the Foundation sell the Building back to the School Corporation. School Corporation officials selected this arrangement because the Foundation was not subject to public bidding laws, and therefore, the renovation could occur more quickly. Plaintiffs, several area contracting businesses paying taxes in the school district, filed an action against the School Corporation and the Foundation (together, “Defendants”) claiming that Defendants violated public bidding statutes and Indiana’s Antitrust Act. The trial court granted Defendants’ motion for summary judgment, determining that the School Corporation engaged in the transactions to circumvent the public bidding statutes but that the transactions were not unlawful. The court of appeals reversed, concluding that the project violated the Public Bidding Laws. The Supreme Court (1) affirmed the portion of the court of appeals’ opinion holding that the scheme used by Defendants violated the Public Bidding Laws; and (2) concluded that Plaintiffs' antitrust claim failed because Plaintiffs did not present evidence of an antitrust injury. View "Alva Elec., Inc. v. Evansville-Vanderburgh Sch. Corp." on Justia Law
Fayette County Bd. of Comm’rs v. Price
Howard Price was the Fayette County Highway Supervisor from 1991 to 2002 and again resumed the position in 2006. In 2011, the Fayette County Board of Commissioners decided not to reappoint Price as Highway Supervisor. Thereafter, Price brought this action requesting a review of the Board’s decision to terminate his continued employment. The Board filed a motion to dismiss, which the trial court treated as a motion for summary judgment, asserting that its employment decision was not subject to judicial review. The trial court denied summary judgment, concluding that the Board’s decision was quasi-judicial in nature and thus subject to judicial review. The court of appeals affirmed on interlocutory appeal. The Supreme Court reversed, holding that the Board’s employment decision with respect to Price was a ministerial decision, not a quasi-judicial one, and therefore not subject to judicial review. View "Fayette County Bd. of Comm'rs v. Price" on Justia Law
Paul Stieler Enters., Inc. v. City of Evansville
In 2012, the Common Council of the City of Evansville enacted an ordinance (“the Amending Ordinance”) that amended an existing smoking ban (“the Smoking Ban”). The Amending Ordinance extended the Smoking Ban to bars, taverns, and eating establishments but exempted riverboat casinos from the Smoking Ban. Various bars and private clubs brought actions against the City and its Council, claiming that the Amending Ordinance was unconstitutional. The trial court upheld the constitutionality of the Amending Ordinance, and the court of appeals affirmed. The Supreme Court reversed, holding (1) on its face, the Amending Ordinance violates the Equal Privileges and Immunities Clause of the Indiana Constitution because the disparate treatment is not reasonably related to the inherent differences between divergently-related classes; and (2) the Amending Ordinance must be stricken in its entirety. View "Paul Stieler Enters., Inc. v. City of Evansville" on Justia Law
Am. Cold Storage v. City of Boonville
The City of Boonville passed an ordinance to annex 1,165 acres of real estate located west of the city limits. Later that year, numerous landowners opposed to the annexation filed written remonstrance and complaint for declaratory relief. The City moved to dismiss, arguing that the Landowners did not satisfy the statutory requirement that at least sixty-five percent of landowners in the annexed territory sign the remonstrance. At issue in this case was whether the sixty-five percent remonstrance threshold was to be determined by separately counting the multiple parcels acquired by the State for an adjoining public roadway or collectively as one parcel. The trial court ultimately determined that the threshold was not satisfied. The Supreme Court reversed and remanded, holding that the land in this case, which comprised the portion of the public roadway included in the annexed territory, should be considered and counted as a single parcel in determining whether the remonstrating landowners comprised sixty-five percent of the owners of the annexed territory. View "Am. Cold Storage v. City of Boonville" on Justia Law
Ind. Gas Co., Inc. v. Ind. Fin. Auth.
The Indiana Utility Regulatory Commission (IURC) approved a contract for the purchase of substitute natural gas and directed the procedure for resolving future related disputes. The court of appeals reversed the IURC's approval of the contract because a definition term in the contract deviated from the required statutory definition. The parties to the contract subsequently amended the contract to delete the language that the court of appeals found improper. The Supreme Court vacated the reversal of the IURC's order, held that the amended contract that corrected the definitional error rendered the definitional issue moot, and summarily affirmed the court of appeals as to all other claims. View "Ind. Gas Co., Inc. v. Ind. Fin. Auth." on Justia Law
In re Mandate of Funds for Ctr. Twp. of Marion County Small Claims Court
This action involved a dispute between a township small claims court and the township trustee and advisory board over changes in the small claims court. The small claims court issued an order for mandate and mandate of funds directing the trustee and advisory board not to move the location of the court, to increase court employees' salary, to provide two new clerk positions, and to renovate the current court building. The township opposed the mandate order. The Supreme Court appointed a special judge to hear the matter. After a trial, the special judge (1) affirmed the mandate order insofar as it approved the additional staff, renovations, and prohibited the relocation of the court; and (2) reversed the portion of mandate ordering salary increases. The Supreme Court affirmed the decree of the special judge, holding (1) the decree correctly prohibited the relocation of the court; and (2) the decree properly directed the township to pay the reasonable attorney fees and expenses incurred by each side in this case. View "In re Mandate of Funds for Ctr. Twp. of Marion County Small Claims Court" on Justia Law
Util. Ctr., Inc. v. City of Fort Wayne
Plaintiff owned and operated certain water and sewer facilities in the City of Fort Wayne. The facilities were divided into two separate geographic areas - the North System and the Aboite System. In 2002 the City passed a resolution appropriating and condemning the North System. The City assessed damages in the amount of $14,759,500. Plaintiff challenged the condemnation proceedings alleging that the City failed to follow the proper eminent domain or condemnation statutes. The trial court granted summary judgment for the City, and the Supreme Court affirmed. The City subsequently reaffirmed its initial resolution appropriating and condemning Plaintiff's North System and adopted a resolution assessing damages in the amount of $16,910,5000. Plaintiff appealed the decision to the trial court and requested a trial by jury. The trial court refused the trial request and granted the City's motion for partial judgment on the pleadings. The Supreme Court reversed, concluding that Plaintiff had a right to the trial court's review of the record which included a full evidentiary hearing before a jury. View "Util. Ctr., Inc. v. City of Fort Wayne" on Justia Law
J.M. v. Review Bd. of Ind. Dep’t of Workforce Dev.
Employer allowed Employee to take a college class during his normal work hours but informed him he would have to use his vacation, compensation, or unpaid time rather than take shorter lunches, come in early, or stay later. Employee enrolled in the class but did not follow Employer's instructions and failed properly to account for his time off. Consequently, Employee was fired and denied unemployment benefits. An ALJ overturned that decision and granted Employee unemployment benefits, concluding that the discipline was too severe for only a small amount of misreported time. The review board of the department of workforce development upheld the original denial of unemployment benefits, finding that J.M. was discharged for just cause and thus ineligible for unemployment benefits. The Supreme Court affirmed the review board's denial of benefits, holding that the findings of fact by the review board showed Employee violated his supervisor's instructions and the employee handbook, which were statutory grounds for just-cause discharge. View "J.M. v. Review Bd. of Ind. Dep't of Workforce Dev." on Justia Law
Shepherd Props. Co. v. Int’l Union of Painters & Allied Trades
In this case, Plaintiff prevailed on its Access to Public Records Act (Act) claim against a public agency and an intervening private party. As required by statute, the trial court awarded Plaintiff attorney's fees. The fees were awarded against both the public agency and the intervening private party, jointly and severally. The private party argued that the Act does not contemplate the award of attorney's fees against an intervening private party and that only the public agency should be liable for the fees. The Supreme Court affirmed the trial court's award of attorney's fees to Plaintiff, holding (1) the Act, in light of the legislature's liberal-construction mandate and the statute's underlying policy, permits the award of attorney's fees against an intervening private party; and (2) in this case, the trial court did not abuse its discretion in its apportionment of liability.