Justia Family Law Opinion Summaries

Christi and August Wohlt owned a company called Echo Systems, Inc., which dealt in cryptocurrencies. Upon dissolving their marriage, they agreed that August would retain all assets of the business, except for some personal electronics that Christi would keep. However, they both forgot that Echo Systems still owned some cryptocurrencies. The issue was whether this oversight made their agreement ambiguous regarding the ownership of these cryptocurrencies.The Delaware Circuit Court dissolved their marriage and incorporated their property settlement agreement. Later, August discovered the forgotten cryptocurrencies and informed Christi. Christi then filed a motion to address the omitted assets and requested the court to divide the cryptocurrencies and increase August’s child support obligation. August moved for partial summary judgment, arguing that the agreement unambiguously awarded him all of Echo Systems’ assets, including the cryptocurrencies. The trial court denied his motion, finding factual issues regarding the parties' knowledge of the cryptocurrencies. After an evidentiary hearing, the court awarded Christi half the value of the cryptocurrencies, concluding the agreement was ambiguous.The Indiana Court of Appeals reversed the trial court’s decision, holding that the property settlement agreement unambiguously awarded the cryptocurrencies to August. The court affirmed the trial court’s rulings on other issues, including attorney and expert fees.The Indiana Supreme Court reviewed the case and agreed with the Court of Appeals that the agreement unambiguously transferred all of Echo Systems’ assets, including the cryptocurrencies, to August. The court emphasized that the term “all” was not ambiguous and that the parties’ agreement intended to settle all their assets with finality. The court reversed the trial court’s denial of August’s motion for partial summary judgment and affirmed the Court of Appeals' decision on the remaining issues. View "Wohlt v. Wohlt" on Justia Law

The case revolves around Sabrina Dunn, who was charged with murder after shooting her ex-husband, Bill Dunn, in her home. The couple had a history of domestic disputes, with Bill exhibiting erratic and abusive behavior, leading Sabrina to obtain multiple protective orders against him. Despite these orders, Bill continued to harass Sabrina, often breaking into her home. On the day of the incident, Bill entered Sabrina's home uninvited, carrying knives. Fearing for her life, Sabrina shot and killed him.The trial court instructed the jury that the State had to prove beyond a reasonable doubt that Sabrina did not act in self-defense “and/or” in defense of her dwelling. Sabrina was found guilty of murder and sentenced to a maximum term of sixty-five years. The Court of Appeals affirmed the conviction but revised the sentence to fifty-five years with five years suspended.The Indiana Supreme Court, however, found that the use of “and/or” in the jury instructions was ambiguous and potentially misleading. The court noted that the jury needed to understand that the State had to prove that Sabrina did not act in either self-defense or in defense of her dwelling. The ambiguous instructions, the court concluded, could have led the jury to believe that the State only needed to disprove one of these defenses, not both. Given the strength of Sabrina's defense-of-dwelling claim, the court found a serious risk that she was wrongly convicted. As a result, the court vacated Sabrina's murder conviction and remanded the case to the trial court for further proceedings. View "Dunn v. State" on Justia Law

The case pertains to a marital dissolution dispute in Indiana where the husband's police pension constituted the majority of the couple's marital estate. The husband was reluctant to share his pension with his wife, expressing his intention to disregard any court order mandating him to do so. As a response, the trial court ordered the husband to secure and subsidize a life insurance policy to ensure the wife received her share of the marital estate. The husband challenged the trial court's authority, arguing that the court did not consider the tax implications of his future pension payments.The Indiana Supreme Court upheld the trial court's decision. It ruled that the trial court had broad statutory authority to order a security or other guarantee, such as a life insurance policy, when necessary, to secure the division of property. The court also held that the husband had waived his challenge regarding the tax consequences of his future pension payments.The facts of the case reveal that the husband and wife had been married for nearly twenty-six years. The husband's police pension had a market value of over $1.1 million, constituting over 85% of the marital estate. The husband was unwilling to share his pension with his wife, and the wife expressed concern that she might not receive anything. The trial court ordered the husband to make monthly payments and obtain a life insurance policy that named her as owner and beneficiary. The husband contested this order, leading to the appeal. The Indiana Supreme Court affirmed the trial court's decision, maintaining that the court had the authority to secure the wife's share of the marital estate through a life insurance policy. View "Cooley v. Cooley" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Father committed an act of domestic or family violence against Child and that he represented a credible threat to the family's safety and thus granting Mother's petition for an ex parte petition order, holding that the trial court's evidence-based findings supported its judgment.Specifically, the Supreme Court held (1) the evidence presented supported the trial court's finding that Father committed an act of domestic or family violence; and (2) Mother presented probative evidence to support the trial court's finding that Father posed a credible threat to Mother or Child's safety. View "S.D. v. G.D." on Justia Law

The Supreme Court dismissed this appeal from a decision of the court of appeals requiring Adoptive Parents to provide notice to biological Father of the temporary custody of Child, rending the trial court's temporary custody order void for lack of personal jurisdiction, holding that this Court lacked appellate jurisdiction.After Child was placed full-time with Adoptive Parents, Adoptive Parents petitioned to adopt child and separately moved for temporary custody. Father was not served the petition or motions. After a hearing, the superior court granted Adoptive Parents temporary custody, determining that it was in Child's best interests while the adoption petition was pending. Father later filed a motion to set aside the order of custody on the grounds that he was not given notice. The trial court denied the motion. Adoptive Parents appealed. The Supreme Court dismissed the appeal, holding that the superior court's order granting temporary custody was not a final judgment because it neither disposed of all claims for all parties nor stated that there was no just reason for delay. View "P.L. v. A.H." on Justia Law

The Supreme Court affirmed the judgment of the trial court in this marital dissolution case, holding that a trial court need not follow a rigid, technical formula in dividing the marital estate so long as the court expressly considers all marital property and offers sufficient justification to rebut the presumptive equal division.In its final decree, the trial court granted Wife's request for spousal maintenance and awarded Wife fifty-five percent of the "net marital estate." On appeal, both Husband and Wife disputed the trial court's award of spousal maintenance and the distribution of the marital estate. The Supreme Court affirmed, holding (1) there was no error in the trial court's award of spousal maintenance; and (2) there was no error in the court's division of marital property. View "Roetter v. Roetter" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Husband had breached a provision of the parties' settlement agreement entered into during their dissolution of marriage action, holding that the trial court did not abuse its discretion in finding that Husband had breached the warranty clause of the agreement.During dissolution proceedings, Wife and Husband signed a settlement agreement under which each party retained all stock accounts in their respective names and Husband received all jointly held stock accounts. The agreement contained a warranty stating that the parties would truly reveal to each other their assets and debts. Wife subsequently filed a motion for relief from judgment, alleging that the agreement should not be enforced due to the omission of a stock account from a balance sheet used in determining the division of assets. The trial court awarded Wife half of the value of the account, concluding that fraud, constructive fraud, mutual mistake, or misrepresentation had occurred. The Supreme Court affirmed, holding (1) Wife's evidence was inadmissible to avoid the agreement, and the trial court incorrectly determined that fraud, constructive fraud, mutual mistake, or misrepresentation had occurred; but (2) the trial court did not abuse its discretion in finding that Husband had breached the warranty clause of the agreement. View "Berg v. Berg" on Justia Law

The Supreme Court affirmed the ruling of the trial court finding that Mother's consent was not required for the adoption of her child, holding that sufficient evidence supported the trial court's determinations.The trial court granted Stepmother's petition for stepparent adoption of Child, finding that Mother's consent was unnecessary because she had failed to pay child support for more than one year, failed significantly to communicate with Child for more than one year, and had abandoned Child. The Supreme Court affirmed, holding that the evidence supported the court's findings that Mother for one year failed significantly to communicate with Child and support Child when able to do so. View "J.P. v. V.B." on Justia Law

In this termination of parental rights case, the Supreme Court affirmed the decision of the trial court to admit drug reports, holding that the trial court properly found that the reports did not fit the records of a regularly conducted activity exception pursuant to Ind. R. Evid. 803(6).The Indiana Department of Child Services filed a petition to terminate Parents' parental rights to their four children. During the termination hearing and over Parents' objections, the trial court admitted drug test results for both parents. The court terminated the parents' parental rights. Parents appealed, arguing that the trial court abused its discretion in admitting their drug test results. The court of appeals affirmed, concluding that the drug test results were properly admitted as records of a regularly conducted activity and that any error in their admission was harmless. The Supreme Court granted transfer and affirmed, holding (1) the drug test records here fell under the records of a regularly conducted business activity; and (2) the trial court did not err in admitting the drug records. View "A.B. v. Indiana Department of Child Services" on Justia Law

The Supreme Court reversed the determination of the trial court finding Mother in contempt of court and ordering that Father have sole legal and physical custody of the parties' infant child, holding that the court abused its discretion by conflating Mother's contempt of court with the best interest of the child.Father filed a petition for rule to show cause alleging that Mother had violated a previous order by relocating the parties' child from Indiana. The trial court granted full relief to Father, finding Mother in contempt for relocating the child out of Indiana and for denying Father parenting time. The court then ordered that Father have sole legal and physical custody of the child. The Supreme Court reversed, holding that where Mother's alleged contempt appeared to be the catalyst for the trial court's order granting Father sole legal and physical custody, the trial court's order could not stand. View "Yanes-Mirabal v. Badasay" on Justia Law