July 31, 2026

Indiana Court of Appeals
David Edmonson v. State of Indiana
No. 25A-CR-2693

Appeal from the Marion Superior Court, Judge Amy M. Jones, Magistrate David M. Hooper. David Edmonson appeals his conviction for Class A misdemeanor cruelty to an animal, arguing that the evidence was insufficient to support his conviction. The court affirms the conviction, concluding that Edmonson’s actions constituted reckless neglect as defined by Indiana law. Evidence showed that Edmonson allowed his dog, Snuggles, to live in deplorable conditions, leading to severe health issues, which could reasonably be interpreted as serious harm. Edmonson’s financial inability to seek veterinary help does not mitigate the evidence of neglect, especially given that he had options to surrender the dog earlier. Judge Foley authored the opinion, and Chief Judge Tavitas and Judge Weissmann concur. Appellant’s attorneys: Talisha R. Griffin, Marion County Public Defender Agency, Indianapolis, Indiana; and Joel M. Schumm, Indianapolis, Indiana. Appellee’s attorney: Office of the Indiana Attorney General.

Indiana Court of Appeals
Hannah Janowiak v. Kenneth Sandage and The Trustees of Purdue University
No. 25A-CT-2937

Appeal from the Marion Superior Court, Judge Kurt Eisgruber. The court affirmed the trial court’s decision, which dismissed Janowiak’s negligence claim against Sandhage and granted summary judgment for Purdue. Janowiak had initially sued Sandhage after being struck by his car, later amending her complaint to include Purdue as a defendant based on Sandhage’s admission that he was acting within the scope of his employment during the incident. However, the court ruled that Janowiak’s claims were barred under the Indiana Tort Claims Act due to her failure to provide timely notice of her claim to Purdue, which was required within 180 days of the injury. The court concluded that Janowiak did not substantially comply with this requirement and that Purdue was entitled to summary judgment. Judge Kenworthy authored the opinion, with Judges Bradford and Pyle concurring. Appellant’s attorney: Sarah Graziano, Hensley Legal Group PC, Fishers, Indiana. Attorneys for appellee Kenneth Sandage: John W. Mervilde and Kevin D. Lichtenberger, Schultz & Pogue LLP, Indianapolis, Indiana. Attorneys for the appellees Trustees of Purdue University: Barry L. Loftus and Danielle K. Fortin, Stuart & Branigin LLP, Lafayette, Indiana.

Indiana Court of Appeals
Steven Watters v. State of Indiana
No. 25A-CR-3310

Appeal from the Posey Circuit Court, Judge Craig S. Goedde. In this consolidated appeal, Steven Watters challenges the revocation of his probation and the denial of his motion to set aside a guilty plea regarding new charges. The court found that Watters did not knowingly, intelligently, unequivocally and voluntarily waive his right to counsel in the probation revocation proceedings, reversing the revocation and remanding for further proceedings. Additionally, the trial court abused its discretion by not following procedural requirements when denying Watters’ motion to vacate his guilty plea, leading to a remand for compliance with procedural rules. Chief Judge Tavitas authored the opinion, with Judge Bradford concurring and Judge Felix concurring in part and dissenting in part, specifically regarding the court’s treatment of the probation admission claim. Appellant’s attorney: Erin L. Berger, Evansville, Indiana. Appellee’s attorney: Office of the Indiana Attorney General.

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