Justia Health Law Opinion SummariesArticles Posted in Supreme Court of Indiana
Mellowitz v. Ball State University
The Supreme Court affirmed the order of the trial court directing that while Plaintiff may pursue his claims against Ball State University based on its response to the COVID-19 pandemic on his on behalf, he may not pursue a class action on behalf of other students, holding that there was no error.Plaintiff, a university student, sued the University for breach of contract and unjust enrichment after the university switched to providing only online instruction for the 2020 spring semester, seeking to recover tuition and fees for in-person instruction and services allegedly promised by the university. Plaintiff sought to litigate his claims as a class action, but after he filed his action, Public Law No. 166-2021 was signed into law, prohibiting class action lawsuits against postsecondary educational institutions for contract and unjust enrichment claims arising from COVID-19. The trial court denied class certification based on this new law. The Supreme Court affirmed, holding that the trial court correctly concluded that the law was constitutional and precluded a class action in this case. View "Mellowitz v. Ball State University" on Justia Law
Members of the Medical Licensing Bd. v. Planned Parenthood Great Northwest, Hawai’i, Alaska, Indiana, Kentucky, Inc.
The Supreme Court vacated a preliminary injunction granted by the trial court preliminarily enjoining the State from enforcing Senate Bill 1, which broadly prohibits abortion but makes exceptions in three circumstances, holding that Plaintiffs could not show a reasonable likelihood of success on their facial challenge.Plaintiffs, several abortion providers, brought this lawsuit seeking to invalidate Senate Bill 1 on the grounds that the law materially burdened a woman's exercise of her right to "liberty" under Ind. Const. Art. I, 1. The trial court agreed and granted the preliminary injunction. The Supreme Court reversed, holding (1) Plaintiffs had standing to contest the constitutionality of Senate Bill 1; (2) Senate Bill 1 was judicially enforceable; (3) Article 1, Section 1 protects a woman's right to an abortion that the extent that it is necessary to protect her life or to protect her from a serious health risk, but, otherwise, the General Assembly retains legislative discretion in determining the extent to which prohibit abortions; and (4) the record in this case did not support a preliminary injunction. View "Members of the Medical Licensing Bd. v. Planned Parenthood Great Northwest, Hawai'i, Alaska, Indiana, Kentucky, Inc." on Justia Law
Miller v. Patel, M.D.
The Supreme Court affirmed the decision of the trial court granting summary judgment for Appellant's mental health providers for not preventing his crime of voluntary manslaughter, holding that Defendant was collaterally estopped from relitigating his responsibility.Appellant pleaded guilty but mentally ill to voluntary manslaughter. Thereafter, Appellant sued his mental health providers, arguing that they were legally responsible for his act. The trial court granted summary judgment for Appellees. The court of appeals reversed. The Supreme Court granted transfer, thus vacating the court of appeals' opinion, and affirmed, holding (1) Appellant was estopped from relitigating his legal responsibility under defensive issue preclusion; and (2) Appellees carried their summary judgment burden of establishing that Appellant's damages were not compensable. View "Miller v. Patel, M.D." on Justia Law
In re Civil Commitment of B.N.
The Supreme Court affirmed the order of the trial court, after a hearing, finding B.N. to be severely disabled and to be in need of extended custody, care, and treatment, holding that the trial court abused its discretion, but the error was harmless.B.N. requested to appear at her commitment hearing in person, but the trial court denied the request, stating, "we're proceeding remotely due to the COVID-19 pandemic." On appeal, B.N. argued that the trial court's denial of her request for in-person hearing violated Administrative Rule 14 and constitutional and statutory provisions. The Supreme Court affirmed, holding (1) the trial court did not make the requisite findings of good cause to conduct B.N.'s commitment hearing virtually; but (2) the trial court's error was harmless. View "In re Civil Commitment of B.N." on Justia Law
In re Commitment of E.F.
The Supreme Court affirmed the judgment of a panel of the court of appeals dismissing an appeal in this temporary commitment case on the grounds that the appeal was moot, holding that "public interest exception" to mootness applied.After a hearing, the trial court found E.F. was gravely disabled and entered a temporary commitment order allowing for her emergency detention. While E.F.'s appeal was pending, the commitment order expired. The court of appeals dismissed E.F.'s appeal as moot, interpreting T.W. v. St. Vincent Hospital & Healthcare Center, Inc., 121 N.E.3d 1039 (Ind. 2019), as disfavoring the practice of applying the public interest exception except in "rare circumstances." The Supreme Court reversed, holding that E.F. should have the opportunity to make certain arguments before the court of appeals. View "In re Commitment of E.F." on Justia Law
Holcomb v. Bray
The Supreme Court reversed in part and affirmed in part the order of the trial court finding that HEA-1123 is constitutional, holding that Governor Eric J. Holcomb was not procedurally barred from seeking declaratory relief on the constitutionality of House Enrolled Act 1123 (HEA-1123) and that the law is unconstitutional.HEA-1123, which was passed during the COVID-19 pandemic, authorizes the General Assembly to commence an "emergency session" under certain conditions through a simple resolution. The Governor vetoed the bill, finding it unconstitutional. The General Assembly overrode the Governor's veto, and the law went into effect. The Governor filed suit. The trial court found the HEA-1123 was constitutional. The Supreme Court reversed, holding (1) HEA-1123 violates Ind. Const. art. III, 1; and (2) by authorizing the Legislative Council to set an emergency session at a time when the General Assembly was not in session, HEA-1123 infringed on constitutional authority vested only in the Governor. View "Holcomb v. Bray" on Justia Law
ResCare Health Services Inc. v. Indiana Family & Social Services Administration
The Supreme Court reversed the judgment of the trial court denying ResCare Health Service's request for a declaratory judgment, holding that ResCare sufficiently pleaded its declaratory judgment request.ResCare, which operates intermediate care facilities in Indiana for individuals with intellectual disabilities, petitioned for administrative reconsideration after an auditor with the Indiana Family & Social Services Administration’s Office of Medicaid Policy and Planning (FSSA) adjusted cost reports to prevent ResCare from recovering costs for over-the-counter medicines under Medicaid. An ALJ granted summary judgment for ResCare. The trial court affirmed the agency's final decision. The Supreme Court reversed, holding (1) ResCare did not need to file a separate complaint for a declaratory judgment; (2) ResCare sufficiently pleaded its declaratory judgment claim; and (3) ResCare's patients did not have to be joined to the litigation before the declaratory judgment request could be considered. View "ResCare Health Services Inc. v. Indiana Family & Social Services Administration" on Justia Law
FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc.
The Supreme Court vacated the trial court's grant of summary judgment for Defendants, holding that the trial court erred by entering summary judgment for defendant health-insurance plans, which were governed by the Employee Retirement Income Security Act of 1974 (ERISA), based on ERISA preemption.Plaintiff, a health-care provider, contracted with two third-party networks. Defendants and its affiliated employee health-insurance plans contacted with both health networks. Seven patients received treatments from Plaintiff, and the patients were covered under Defendants' plans. Plaintiff sued Defendants, alleging that they failed to pay agreed reimbursement rates for covered services under their plans. The trial court granted summary judgment against Plaintiff, concluding that Plaintiff's claims were preempted under ERISA's conflict-preemption provision, 29 U.S.C. 1144(a). The Supreme Court vacated the judgment, holding that genuine issues of disputed fact existed concerning the central issue of whether the provider's claims were denied coverage under the plans or whether the provider's claims necessitated interpreting the plan documents. View "FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc." on Justia Law
In re Civil Commitment of T.W. v. St. Vincent Hospital & Health Care Center, Inc.
In these two mental health cases, the Supreme Court dismissed the appeals of the temporary commitment orders of two individuals, holding that the Probate Commissioner lacked authority to enter the commitment orders.Although the appeals were moot, the Supreme Court addressed an issue of great public importance likely to recur, that issue being whether the Commissioners lacked authority to enter the orders of civil commitment. On appeal, Appellants argued that, rather than issuing a commitment order, the Commissioner approved each order via an "approval order" that did not constitute valid commitment orders for these two mental health cases. The Supreme Court agreed, holding that the approval orders provided inadequate assurance that the Commissioner was presented with, reviewed, and approved the temporary commitment orders in the cases of the two individuals at issue here. View "In re Civil Commitment of T.W. v. St. Vincent Hospital & Health Care Center, Inc." on Justia Law
A.A. v. Eskenazi Health/Midtown CMHC
In this involuntary civil commitment proceeding, the trial court accepted an invalid waiver of A.A.’s right to personal appear, and that error was not harmless.A.A.’s attorney waived A.A.’s right to appear, and the involuntary commitment hearing proceeded without him. The trial court ultimately ordered involuntary civil commitment. The Supreme Court reversed and remanded for the trial court to vacate the regular involuntary-commitment order, holding (1) a mentally competent civil-commitment respondent may relinquish the right to appear with a knowing, voluntary, and intelligent waiver, but an attorney may not waive the right to appear on the respondent’s behalf; (2) if the trial court independently waives a respondent’s presence at a commitment hearing, it must do so at the outset of the proceeding; (3) an improper waiver determination is subject to harmless-error review; and (4) in this case, the trial court did not make a proper waiver finding at the outset of A.A.’s involuntary civil-commitment proceeding, and the error was not harmless. View "A.A. v. Eskenazi Health/Midtown CMHC" on Justia Law