Feb. 16, 2026

Indiana Court of Appeals
Eric D. Wilson v. State of Indiana
No. 25A-CR-1542
Criminal. Appeal from the Morgan Superior Court, Judge Brian H. Williams. Reverses Wilson’s conviction of Class C misdemeanor operating a vehicle while intoxicated. Holds that Deputy Caleb Merriman lacked reasonable suspicion to initiate the investigatory traffic stop where Wilson was observed making “jerky” and fidgeting body movements but committed no traffic violations and exhibited no erratic or unusual driving behavior. Concludes that, under the totality of the circumstances, the deputy’s observations amounted to a hunch rather than specific, articulable facts of criminal activity and therefore violated the Fourth Amendment. Further holds the stop was unreasonable under Article 1, Section 11 of the Indiana Constitution after balancing the Litchfield factors, noting the moderate intrusion of field sobriety tests, transport to a hospital and a blood draw, and the absence of law enforcement need supported by traffic violations or abnormal driving. Determines the trial court abused its discretion in admitting evidence obtained as a result of the stop. Attorney for appellant: Glen E. Koch II. Attorney for the appellee: Office of the Indiana Attorney General.

Indiana Court of Appeals
Velox Express, Inc., and James R. Gibson v. Darryl Brent Waltz, Jr.
No. 25A-PL-1499
Civil. Interlocutory appeal from the Johnson Superior Court, Special Judge R. Scott Sirk. Reverses the trial court’s denial of Velox and Gibson’s second motion for summary judgment and remands with instructions to grant the motion. Holds that Waltz’s claims alleging breach of fiduciary duty, theft, fraud and breach of contract arise from alleged mismanagement and self-dealing that harmed the corporation and reduced the value of his shares, making them derivative in nature rather than direct claims. Concludes Waltz failed to designate evidence showing that the limited exception for closely held corporations applies or that the company’s special litigation committee was not disinterested or failed to conduct a good-faith investigation. Further holds that under Indiana Code section 23-1-32-4(c), the special litigation committee’s determination that pursuing the claims was not in the corporation’s best interests is presumed conclusive and bars the derivative action. Attorneys for appellants: Benjamin C. Fultz; Eric W. Prime; Michael W. Oyler. Attorney for appellee: Paul L. Jefferson.

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