Court opinions

Indiana Supreme Court
Jesse L. Payne v. State of Indiana
20S-CR-313
Criminal. Reverses the guilty but mentally ill verdict and aggregate 90-year sentence for Jesse Payne after he confessed to burning down two covered bridges in Parke County. Finds the state presented insufficient demeanor evidence to rebut both the unanimous expert opinion that Payne is legally insane and Payne’s “well-documented history of mental illness.” Remands for the trial court to hold a hearing for Payne’s involuntary commitment under Indiana Code section 35-36-2-4. Justice Mark Massa dissents with a separate opinion joined by Justice Geoffrey Slaughter.

Indiana Court of Appeals
A.S. v. Indiana University Health Bloomington Hospital
19A-MH-3044
Mental health. Affirms A.S.’s 90-day commitment to Indiana University Health Bloomington Hospital. Finds the Monroe Circuit Court did not admit into evidence the hearsay about which A.S. complains. Finds testimony from a doctor provided clear and convincing evidence that A.S. was gravely disabled and that forced administration of antipsychotic medication was warranted.

Indiana Court of Appeals
Frances L. Batchelder, Special Administrator of the Estate of John E. Batchelder, M.D., Deceased v. Indiana University Health Care Associates, INC, d/b/a IUHP
19A-CT-2569
Civil tort. Reverses the Marion Superior Court’s award of summary judgment in favor of Indiana University Health Care Associates, Inc., in the medical malpractice action brought by Frances Batchelder, special administrator of the estate of John E. Batchelder, M.D. Finds that by prematurely applying the $1.25 million setoff from a settlement with a third party to the statutory limit and offsetting the IUHP judgment to zero, without first determining the value of the estate’s case, the trial court denied the estate the potential full recovery to which the estate is legally entitled. Remands for proceedings.

Indiana Court of Appeals
Tiffany Abbott, Cathie Barnes, and Chandra Gray v. Individual Support Home Health Agency, Inc.
19A-PL-2367
Civil plenary. Reverses the Henry Circuit Court’s order denying the motion to dismiss the complaint filed by Tiffany Abbot, Cathie Barnes and Chandra Gray’s former employer, Individual Support Home Health Agency, Inc. Finds the women’s reports to the Indiana State Department of Health are protected by absolute privilege because the reports initiated a quasi-judicial proceeding. Finds the trial court erred when it denied their motion to dismiss Home Health’s complaint. Remands the case to the trial court with instructions to dismiss Home Health’s complaint.

The following Indiana Supreme Court opinion was posted after IL deadline on Monday.
FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc., et al.
20S-PL-302
Reverses grant of summary judgment in favor of Meritain Health, University of Notre Dame and Beacon Health. Finds the St. Joseph Superior Court erred in concluding FMS’s claims were preempted under the conflict-preemption provision of the Employment Retirement Income Security Act of 1974. Determines FMS’s state-law claims survive the two-pronged compete preemption test developed in Aetna Health, Inc. v. Davila, 542 U.S. 200, 210, (2004). Rules the precedent set in Midwest Security Life Insurance Co. v. Stroup, 730 N.E. 2d 163 (Ind. 2000) was misconstrued and that FMS’s claim does not involve ERISA but rather is about a provider’s rate of payment under a separate contract with a health insurance plan. Remands for further proceedings.