HomeMy WebLinkAbout02) BridgeviewBridgeview Center, LLC,
Plaintiff
YS.
In The Clark Circuit Cot~r~
state of Indiana
Cause:
10C01-0203-PL-230
Special Judge L, Whitis
The City of Jeffersonville, Indiana,
Et. Al.,
Defendants
City of Jeffersonville's Response to Bridgeview's
Obiection to New Trial
Comes now the Defendants (City), by counsel, Larry Wilder, and for its
,esponse to the Plaintiff's (Bddgeview) objection to a new trial sets forth the
following:
I. Facts
' ' -This case was tried before Judge Terrence Cody on two-(2) separate days
ending in September of 2004. The trial court heard evidence from four (4)
witnesses that s 9armed at least sixteen (16) hours. Bridgev~ew had the burden of
proof uoon its claims of slander of title and inverse conaemnation. Moreover,
3ridgeview had the burden of proving that it suffered damages if it could meet the
Burden of proof upon those torts. Much, f not a of Bridgeview's case rested
upon the credibil ty of the witnesses it presented at trial. The City presented
testimony to rebut Bridgeview's position on both liability and damages.
The court ordered the parties to exchange their proposed findings of fact
and conclusions of law by December 6, 2004. The parties complied. Pursuant to
Trial Rule 53.1 Judge Cody had ninety (90) days from the conclusion of the trial to
rule upon the case. He failed to do so and the City requested the case be
removed from his consideration.
The Clerk of the Clark Circuit Court reviewed the record and submitted the
matter to the Indiana Supreme Court for assignment of a new judge. After
objection by Bridgeview the Supreme Court appointed Judge Cile Blau of the
Clark Superior Court II.
Judge Blau conducte~l a pie-trial conference and scheduled the matter for
hearing. Before the hearing Bridgeview filed a motion requesting the court recuse
the City's attorney on various grounds. Judge Blau oenied Bridgeview's request
and again set the matter for hearing.
......... Prior to hearing Bridgewew filed a motion req~¢st_ing Judge Blau ,ecuse
nerself. Bridgewew asserted Judge Blau had a conflict of interest. It was
Bridgeview's contention that Judge Blau owned real estate in Jeffersonville and
her ruling, if favorable for Bridgeview, could adversely effect her property tax rate
Dy caustng it be increased to pay the multi-million dollar luogment that Bridgeview
reouested. Therefore, Bridgewew opineo that the Judge had a "self-interest" in
the result of the case.
Judge Blau recused herself over the objection of the City. The recusal was
sua sponte. After Judge Blau recused herself the case was submitted to Judge
Frank Newkirk for appointment of another judge.
Judge Newkirk appointed Judge Susan Orth of Floyd Superior Court.
Judge Orth refused to accept jurisdiction and the case was returned to Judge
Newkirk. Judge Newkirk, upon receipt of notice of Judge Orth's denial, appointed
Judge H. Lloyd Whitis to hear the case. Judge Whitis assumed jurisdiction and
conducted a pre-trial conference. -
Judge Whitis informed the parties that he was unable to rule upon the
"cold" transcript absent a stipulation by the parties setting forth that they agreed
ti~at the testimony of all witnesses was reliable and credible. Judge Whirls
tnformed that if the parties were unable to enter into such a stipulation he would
schedule the matter for a new trial. The Judge opined that he felt that without the
stipulation to decide the case on the "cold" transcript would constitute "reversible
error".
The City Cou ncil of Jeffersonville determined that it was unwilling to
authorize its attorney to stipulate to the credibility of the witnesses. Judge Whirls,
upon receipt of notice of the City's position, scheduled the matter for ore-trial. At
the pre-trial Bridgeview submitted its objection to scheduling a new trial.
II. Issue:
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Does Judge Whitis have the authority to order a new trial in this
matter?
III. Le al~ment:
A. If Judge Whitis Fails to Order a New Trial The City of Jeffersonville's
Constitutional Riqht to Due Process Law Would Be Violated.
Indiana law has established that due process requires the trier of fact hear
all of the evidence necessary to make a meaningful evaluation of a case. If the
trier of fact rules upon a matter without benefit of hearing the evidence this
constitutes a denial of due process. Miller v. Industrial Hardwoods Corp., 7?5
N.E.2d 1168 (Ct. App. 2002).
In Urbanational Developers, Inc., v. Shamrock Eng., 372 N.E.2d ?42
(Ct. App. 1978) the parties enterec into a contract for construction. During the
course of the project disputes arose regarding payment and other ~ssues involving
construction. Shamrock sued Urbanational alleging that Urbanational breached
the contract and owed it money. A trial was held and Uroanational was awarded
judgment against Shamrock. Sk~m-r~)ck filed a Motion to Correct Errors. The trial
judge failed to rule on Shamrock's Motion to Correct Errors within the thirty (30)
Qays allowed and a new judge was appointed by the Indiana Supreme Court
pursuant to Trial Rule 53.1.
The successor judge ordereo a transcript of the proceedings aha after
on Shamrock's Mot on To Correct Errors, amended the
hearing argume.nts
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judgment nearly tripling the amount Shamrock owed Urbanational. Shamrock
appealed the successor judge's decision aIleging that the successor judge should
not have been permitted to rule upon the Motion to Correct Errors since the
successor judge had not heard the original trial.
The Court of Appeals found that the successor judge was granted all of
those rights, duties and powers set forth in Trial Rule 63(A) which sets out in
pertinent part that:
Rule 63. Disability and unavailability of a judge.
(A) Disability and unavailability after the trial or hearing. The judge who presides
at the thal of a cause or a hearing ar which evidence is received shall, if available,
hear motions and make all decisions and rulings required to be made by the court
relating te the evidence and the conduct of the thai or heating after the trial or
hearing is concluded. If the judge before whom the thai or hearing was held is not
available by reason of death, sickness, absence or unwillingness m act, then any
other judge regularly sitting in the judicial circuit or assigned to the cause may
perform any of the duties to be performed by the court after the verdict is resumed
or the findings or decision of the court is filed; but if he is satisfied that he cannot
perform those duties because he did not preside at the thal or for any other reason,
he may in h/s discretion grant a new trial or new hearing, in whole or m pm. The
unavailability of any such trial or hearing shall be determined and shown by a com-r
order made by the successor judge at any time.
The court found'that (fi~re are times that, "...the successors judge's failure
to preside at trial renders him ill-equipped to perform the functions of the regular
trial judge. One of these instances occurs when he ~s confronted with an issue
which requires for its resolutic q a determination of the credibility of witnesses or
the weight to De accorded certain evidence." Urbanational, at 421. Further. the
Urbanat onal court conc uded that "When a successor juoge attempts to resolve
~: -:-. ........ _ _ ..: _:
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questions of credibility and weight of evidence without having had an opportunity
to hear the evidence and observe the demea nor of witnesses he is depriwng a
party of an essential element of the trial process. Such an undertaking by the
successor judge is against the logic an(~ effect of the facts and circumstances
before the court and amounts to an abuse of discrebon. Urbanationat. Ibid.
The court held that a refusal to permit the successor judge to conduct a
new trial would be contrary to Trial Rule 63 as well as violate the parties due
process rights. The court found that, "To nold otherwise would be to grant a .
power of review to the successor judge that is not even claimed by the appellate
court."
This tenet was upheld in Holmes v. Holmes, 726 N.E.2d 1276 (App. Ct.
2000), a child support, visitation and custody case. In Holmes the o_riginal divorce
was entered in Michigan. Both parties moved to Indiana however, several legal
proceedings were conducted in Michigan before the mother requested that the
case be removed to Indiana.
Upon remo~/al to Indiana a hearing was held on the child support issue.
The father was unhappy with the ruling of the presiding judge, Donald Leicht, and
appealed Judge Leicht's order to the Indiana Court of Appeals. The Court of
Appeals reversed Judge Leicht and remanded the matter for additional findings of
fact. Unfortunately, before the case was returned tc the trial cour~ Judge Leicht
was defeated in the General Election and Julian Ridlen was the new Circuit Court
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judge.
The mother, who was the benefactor of Judge Leicht's ruling, requested
that the court appoint Judge Leicht to enter the additional findings of fact. The
father objected and a hearing was held to determine whether or not the case
should be ~eard by Judge Leicht. Judge Ridlen, after hearing argument from the
parties, determined that he was the appropriate party to determine the matter.
After making this determination Judge Ridlen conducted a hearing in which the
parties testified and he reopened the record of the original proceeding and took
additional evidence regarding the case in chief. After hearing the parties
testimony and reviewing the additional evidence Judge Ridlen ruled. The mother,
unhappy with the result, appealed the ruling to the Court of Appeals.
The mother argued that Judge Ridlen erred when he (~egpened the record
and heard tesimony. She also contended that the appropriate judge to hear the
case was Judge Leicht, since he was the original trial judge. T_he court disagreed.
The court stated that:
"'Indiana Trial Rule 63(A) allows a successor judge to perform any
post.trial duties which the judge who conducted the trial or hearing
could have performed. The rule provides that 'if a judge is satisfied
that he cannot perform those duties because he did not preside at the
trial or for any other reason, he may in his discretion grant a new trial
or new hearing, in whole or in part.' This rule contemplates that the
successor judge may not feel comfortable relying solely upon the
transcript of evidence from the trial to render a decision." Holmes, at
1281, See AIso, State Ex. Rel, Harp v. Vanderbur.q Circuit Court, 85
N.E. 2d 254 (Supreme Court found that the death of a judge
subsequent to hearing a case, but before rendering a decision
cOn-stituted grounds for' ne~v~udge to conductnew tria/); Dawson Et.. '-: --"
_?-
Al., v. Wri.qht, Mayor, etc., 12g N.E. 2d 796 (Supreme Court
reemphasized that due process mandates that judge who rules upon
case has opportunity to try and hear evidence).
The law in Indiana is clear inasmuch as it acknowledges that litigants have
a constitutionally protected right to due process. Further, the courts have
established that this right mandates that a jucge who determines litigants fate
shall nave been the judge who heard the evidence upon which ne is ruling.
Therefore, Judge Whirls has the right to order a new trial and the City of
Jeffersonville nas tr~e constitutional right to nave the successor judge hear the
evidence at the new trial.
Jeffersonville Did Not Stipulate To Allow Judqe Whitis To Rule Upon
the "Cold Record"
Bridgeview argues that Jeffersonville waived its due process rights by filing
a motion with the court requesting the transcript of the prior trial be prepared and
submitted to ti~e successor judge. Bridgeview relies upon the holding in Farrier v.
"-l~'a~:~e~-480 N.E.2d 251 (Ct. App. 1985) to support thi~ contention..
Famer was a will contest emanating from the Tippecanoe Circuit Court. In
Farner the relatives left out of the will appealed an adverse cecision denying their
claims of undue influence and challenges of corn petency. The case was, "..heard
and Transcribed by the Tippecanoe Circuit Court. Pursuant to Indiana Trial Rule
53..1 .ant. 53.2 a special judge was a_P.l~inted to render a de_cisio.n basedo~ !h_e
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stipulated record and transcript of the evidence without hearing any new
evidence."
The Court of Appeals opined that the general rule in Indiana "...in such
case is that a successor judge may not make findings of fact or conclusions of law
without a trial de novo." Farner, at 257. The court went on to note that "This is
because '(a) party to an action is entitled to a determination of the issues by the
jury or judge that heard the evidence." Ibid.
However, the court found that an exception to the rule existed in
circumstances wnere the parties stipulate the record and agree to allow the
successor judge to rule upon the "cold" transcript. The court found that:
"In a case where the resolution of a material issue requires a
determination as to the weight and credibility of testimony, due
process requires that the trier of fact hear all of the evidence
necessary to make a meaningful evaluation. However, we find that
like other elements of due process, this right may be waived. Thus,
when the trial judge who heard the testimony and observed the
demeanor of the witnesses at the trial is unavailable to render a
decision thereon, the parties may stipulate that the substitute judge
should determine the case on the record." Farrier, at 258.
.... - ----~- ...... Juoge Whitis asked the parties to c°nsid~' ~r~tering into a stipulated
............ ~greement acknowledging the credibility ofthe'witnesses. The·City Council of
Jeffersonville was unwilling to enter into such a stipulated agreement. Judge
Whitis informed the parties at the pre-trial conference that it was his opinion that if
the parties did not stipulate to the credibility of the witnesses the lack of the
st pulat on wou d const lute revers b e error Judge Wh~t~s ~s correct
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The City and the taxpayers of Jeffersonville have a cor~stitutional!y
protected right to due process of law. Judge Whiffs recognized this constitutional
right exists and inquired as to whether or not the parties were willing to waive their
due process rights and submit the case upon stipulation for ruling upon the "cold"
record. The City Council, the watchdogs elected by the citizens, determined that
they were unwilling to authorize the waiver of this constitutional right. Therefore,
Judge Whitis, correctly, set the matter for trial de novo.
C. .Judqe Whiffs Has The Authority to Order a New Trial,
The issue before the court was specifically addressed in State v. Erlewein.
755 N.E. 2d 700 (Ct. App. 2001). Erlewein was charged with Battery as a Class A
Misdemeanor. Honorable Frank Messer, Jr. hearc the case after several delays.
&t the close of the State's evidence Erlewein moved for a directed verdict arguing
that the State had failed to prove venue. Judge Messer took tf~e venue issue
under advisement and continued with the trial. At the conclusion of all of the
evidence Judge Messer informed the parties that he would take the entire case
uneer advisement. The trial concluded on SepTember 13, 1999.
On February 29, 2000 the prosecutor filed with the trial court a Praecipe for
With(]rawal of Jurisdiction and Transfer to the Supreme Court. On May 30, 2000
the Indiana Supreme Court issued an order appointing Daniel Pflum as Special
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On April 23, 2001 Judge Pfium directed the parties to provide a
memorandum setting forth whether the parties believed that Judge Pflum coutd,
"...review the record of proceedings to determine if the State proved venue.
If not then the Court would have to declare a mistrial. If a mistrial is declared
would the new trial constitute double jeopardy."
On July 25, 2001 Judge Pflum, sua sponte, declared a mistrial after
reviewing the parties, memorandum and the tape of the bench trial. Moreover,
Judge Pflum ordered the parties to file a memorandum on whether or not a new ......
trial would violate double jeopardy. The prosecutor requested the judge
reconsider his eecision ordering a mistrial and a new trial. Judge Pflum denied
this request and found that, "The court being duly ordered will not reconsider
it's declaring a mistrial and it will not and cannot judge the credibility of the
two witnesses without seeing the evidence as they testify."
Judge Pflum, subsequent to declaring a mistrial, ruled tl~at Edewein could -
not be retriec because double jeopardy attacned. The prosecutor appealed the -
court's determination asserting that it was error for the court to order the new trial.
The Indiana Court of Appeals agreed with the State inasmuch as it found
that double ieopardy had no(attached as a result of the Trial Ru[e 53.1 motion
however, the court did qot agree with the prosecutor's contention that a "new trial"
was prohibited uneer the circumstances. The court opined that.
"a ears that Special Judge Pfium viewed the State's
......... It. pp ..... . ..... -'~ ~-:-~^ *he trial'(~o~rt int~'sUa'sponte ~
Trial Rule 53 motion as a mean~ ~u ,u,,.~ -
demeanor of witnesses, he is depriving a party of an essential element of the trial
process. Such an undertaking by the successor judge is against the logic and effect of
the facts and circumstances before the court ane amounts to an abuse of discretion."
The Judge acknowledged that absent such stipulation rulin9 upon the "cold"
record would constitute "reversible error". Clearly, the Judge understood that violation of
either parties due process rights would constitute error.
Respectfully Submitted:
~ O"~/V-ila~,r,~k'~ne~-at Law~
530 Ea§t Cou~venue
jeffersonville, Indiana 47130
Tx: 812.2828.6820Fax: 812.282.3188
Indiana Sup. Ct. 11443-10
Ce~icat~e~ice
I, LarW Wilder, affirm that I have mailed a copy of the above document to the
acin a copy of same in the United States ~1 postage prepaid
below attorney, ,~Y P g .... k,~ n~r onal deliver on this ~ . day of . ,
/or b providing a ¢~Y of sam~ ~.P~ .., ~_.,.. ~*-~t New Albany, Inaiana
~ Y ?0 John Kra~ ~ vv. op-,,~ ..... ,