Feb. 24, 2026

Indiana Supreme Court
Ajaylan M. Shabazz v. State of Indiana
No. 25S-CR-183

Criminal. Appeal from the Allen Superior Court, Judge David Zent, on petition to transfer from the Indiana Court of Appeals. Affirms Shabazz’s murder conviction and 63-year sentence. Holds the trial court abused its discretion under Interim Administrative Rule 14(C) by permitting a key witness to testify remotely at trial because the State failed to present case-specific evidence showing that in-person testimony would cause a concrete and substantial harm and that remote testimony was necessary to prevent that harm. Clarifies that when the State seeks to present remote testimony against a criminal defendant, it must show good cause through particularized evidence that in-person testimony would likely result in a concrete and substantial harm that cannot be mitigated by reasonable measures short of remote testimony, and that generalized concerns about inconvenience or resource constraints are insufficient. Concludes, however, that the error was harmless under Appellate Rule 66(A) in light of overwhelming independent evidence of guilt, including eyewitness testimony, forensic evidence and Shabazz’s own admissions, and therefore affirms. Appellant’s attorney: Gregory L. Fumarolo. Appellee’s attorneys: Office of the Indiana Attorney General.

Indiana Supreme Court
Indiana Land Trust #3082 and Omar and Haitham Abuzir, as Trustees v. Hammond Redevelopment Commission et al.
No. 25S-PL-141

Civil. Appeal from the Lake Superior Court, Judge Bruce D. Parent, on petition to transfer from the Indiana Court of Appeals. Affirms the trial court’s grant of the defendants’ Trial Rule 12(B)(6) motion to dismiss the landowners’ abuse-of-process complaint arising from a pending condemnation action. Holds that the mayor and individual members of the Hammond Redevelopment Commission are immune under Indiana Code section 34-13-3-5 because their alleged conduct — voting for and approving the condemnation resolution and related actions — was of the same general nature as that authorized by statute and undertaken in furtherance of their official duties. Further holds that all defendants — including the commission and the city — are immune under Indiana Code section 34-13-3-3(a)(6) because the landowners’ claimed loss directly resulted from the initiation of a judicial proceeding, namely the condemnation action, and subsection (6) immunity applies to both the initiation and prosecution of such proceedings. Declines to address whether a parallel abuse-of-process claim may proceed alongside a condemnation action in light of the dispositive immunity ruling. Appellants’ attorneys: Greg A. Bouwer; Jeffrey R. Carroll; Karol A. Schwartz. Appellees’ attorneys: Robert J. Feldt; Erika N. Helding; David C. Jensen; Kevin C. Smith; David W. Westland.

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