Articles Posted in Supreme Court of Indiana

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Under Indiana Code section 31-25-2-5, no family case manager at the Indiana Department of Child Services can oversee more than 17 children at a time who are receiving services. The statute does not require the Department to perform any specific, ministerial acts for achieving that number. Price, a family case manager, filed a proposed class action. She alleged that her caseload was 43 children and sought an “order mandating or enjoining [D]efendants to take all necessary steps to comply with [Section 5].” The Indiana Supreme Court affirmed the dismissal of Price’s claim prior to class certification. Judicial mandate is an extraordinary remedy—available only when the law imposes a clear duty upon a defendant to perform a specific, ministerial act and the plaintiff is clearly entitled to that relief. The statute at issue does not impose a specific, ministerial duty. View "Price v. Indiana Department of Child Services; Director of Indiana Department of Child Services" on Justia Law

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When an individual reported child abuse, the Indiana Department of Child Services (DCS) told the reporter that his report was confidential. The Department however, released the report without redacting the identity of the reporter. The reporter and his family sued DCS for negligently disclosing the reporter’s identity, claiming that the statute requiring DCS to protect reporter identity - Ind. Code 31-33-18-2 (section 2) - implies a private right of action and that DCS created a common-law duty of confidentiality. The trial court granted summary judgment for DCS. The court of appeals reversed, concluding that DCS owed Plaintiffs a common-law “private duty” based on a hotline worker’s “promise” of confidentiality. The Supreme Court granted transfer, thereby vacating the Court of Appeals decision, and held (1) section 2 provides no private right of action; and (2) there is no common law basis to impose a duty on DCS. View "John Doe #1 v. Indiana Department of Child Services" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing this action brought by the Board of Commissioners of Union County (Union County) seeking a declaratory judgment and an injunction against the Commissioner of the Indiana Department of Transportation and the Department itself (collectively, INDOT). In the action, Union County alleged that INDOT was negligent in its highway repair efforts, causing damage to the septic systems of three landowners in Union County. The trial court granted INDOT's motion to dismiss, concluding that Union County did not have standing to sue INDOT for injury done to its residents. The Supreme Court affirmed, holding that the trial court did not err in dismissing the action because Union County failed to plead any viable theory of standing to support its alleged cause of action. View "Board of Commissioners of Union County v. McGuinness" on Justia Law

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The Supreme Court reversed the trial court’s order directing the Indiana Alcohol and Tobacco Commission to grant Spirited Sales, LLC’s (Spirited) application for a liquor wholesaler’s permit and reinstated the Commission’s order denying the permit. Spirited was a wholly owned by a parent company called E.F. Transit, Inc. (EFT), which transports beer, wine, and liquor throughout the state. The same shareholders that owned EFT also wholly owned Monarch Beverage Company, Inc, an Indiana company that held a beer and wine wholesaler’s permit. The Commission denied Spirited’s application on the grounds that EFT and Monarch operated as the same company. The trial court reversed, finding the Commission’s order to be arbitrary and capricious. The Supreme Court agreed with the Commission, holding that the Commission’s denial conformed with the clear and unambiguous language of Ind. Code 7.1-1-2-1 and that the Commission did not act arbitrarily or capriciously in denying Spirited’s request. View "Indiana Alcohol & Tobacco Commission v. Spirited Sales, LLC" on Justia Law

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Kristy Burnell’s driver’s license was administratively suspended on the grounds that Burnell failed to submit to a chemical test. Burnell sought judicial review. The trial court declined to set aside the suspension, concluding that the arresting officer correctly determined Burnell’s behavior to constitute a refusal. Burnell appealed, arguing that she never verbally refused to take a chemical test and that her conduct did not constitute refusal to submit to a chemical test. The Court of Appeals affirmed. The Supreme Court affirmed, holding that a reasonable person in the officer’s position would be justified in believing that Burnell manifested an unwillingness to submit to the test. View "Burnell v. State" on Justia Law

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Pursuant to 2011 amendments to statutes addressing collective bargaining for teachers and their employees, when parties failed to reach a collective bargaining agreement (CBA) regarding salaries and wages, the Indiana Education Employment Relations Board (IEERB) appoints a mediator. If the mediation fails, the parties must exchange their last best offers (LBOs). A factfinder appointed by the IEERB then selects which side’s LBO to adopt as the CBA. In this case, a teachers association appealed a factfinder’s decision to adopt a school’s LBO. The IEERB affirmed the factfinder’s decision. The Supreme Court affirmed, holding that the adopted LBO was collectively bargained and lawful. View "Jay Classroom Teachers Ass’n v. Jay School Corp." on Justia Law

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In an effort to benefit from a growing customer base in Hamilton County, Ed Martin Toyota requested, and Toyota Motor Sales, U.S.A., Inc. planned to approve, that Ed Martin relocate from its Anderson, Madison County location, where it operated for several years, to the Fishers area. Prior to the move, Toyota informed its other new motor vehicle dealerships in the region, including Andy Mohr Toyota, Butler Toyota, and Tom Wood Toyota (“Dealers”), and it filed the relocation plan with the Auto Dealer Services Division of the Office of the Indiana Secretary of State (“Division”). Those three dealerships protested the relocation. The Auto Dealer Services Division dismissed their action for lack of standing—affirmed by the trial court, concluding the dealerships were outside the “relevant market area,” as defined by the Indiana Dealer Services Act. Finding that the Division's interpretation of that statutory definition was reasonable, the Supreme Court affirmed the Division's decision. View "Andy Mohr West v. Ind. Secretary of State, Auto Dealer Services Div." on Justia Law