Subscriber Benefit
As a subscriber you can listen to articles at work, in the car, or while you work out. Subscribe Now
Guilty pleas have the same preclusive effect as trial verdicts, a split Indiana Supreme Court ruled in affirming a trial court’s decision to enter summary judgment for mental health providers sued by a man who pleaded guilty but mentally ill to voluntary manslaughter.
In the third round of appeals stemming from Zachary Miller’s killing of his grandfather, the high court was asked to consider Miller’s allegations that his mental health providers essentially didn’t prevent his crime.
In 2018, while his criminal prosecution was pending, Miller filed a proposed complaint for damages with the Indiana Department of Insurance, alleging his providers’ care and treatment “failed to comply with the applicable standards of care.” He further argued that as a direct result of that failure, he “suffered and will continue to suffer from permanent injuries and disabilities, great pain, emotional distress, mental trauma and loss of freedom.”
Miller also added a claim for negligent infliction of emotional distress.
Miller said during proceedings that because of the providers’ negligent conduct, he killed his grandmother’s dog and his grandfather. He argued that the providers caused injury to him by not admitting him to the hospital, and that his grandmother’s dog and his grandfather would be alive if they did.
Miller filed an anonymous complaint in 2019 for damages with the Howard Superior Court. He pleaded guilty but mentally ill to voluntary manslaughter in 2020 and was sentenced to 20 years, with 12 executed.
The Indiana Medical Review Board determined in 2020 that the defendants failed to comply with the appropriate standard of care as charged in the complaint and that the “conduct complained of was a factor of the resultant damages.”
Miller then filed a motion for leave to amend the complaint in the trial court to identify the previously anonymous providers.
The providers moved for summary judgment under Indiana Trial Rule 56(C), arguing that Miller’s alleged damages weren’t compensable under Indiana policy and that Miller was collaterally estopped from relitigating his responsibility for the crime.
The trial court granted the motion and Miller appealed, arguing that he should be allowed to “rebut the prima facie case and prove he was insane at the time of the assault,” and that he didn’t “commit an intentional act.”
The Court of Appeals of Indiana reversed and remanded, finding the providers failed to establish there were no genuine issues of material fact warranting summary judgment because it was “unclear” whether Miller was legally responsible for his act.
The Court of Appeals, relying on a Supreme Court of Illinois opinion, also found collateral estoppel didn’t bar Miller’s action because the issue of whether he was criminally insane when he killed his grandfather was not fully and fairly litigated when he entered his plea agreement.
The Supreme Court granted transfer in November 2022 and noted Miller did not file a brief responding to the providers’ petition for transfer.
A majority of justices affirmed the trial court’s grant of summary judgment, ruling in part that collateral estoppel can be applied to Miller because he “enjoyed his day in court” and “reasonably weighed the costs and benefits of whether to enter a guilty but mentally ill plea, or press on and challenge his fault at trial.”
Justice Mark Massa wrote for the majority that also included Justices Geoffrey Slaughter and Derek Molter.
Chief Justice Loretta Rush concurred in part and dissented in part with a separate opinion, which Justice Christopher Goff joined.
In a matter of first impression, the majority first ruled Miller is estopped from relitigating his legal responsibility under defensive issue preclusion.
Miller’s guilty plea, the court ruled, constituted a final judgment on the merits. His medical malpractice claim “turns on the theory that he was insane at the time of the killing,” the opinion says, but Miller’s mens rea was already established by his guilty but mentally ill plea, so he was essentially attempting to relitigate the same issue adjudicated in the prior proceeding.
The majority also ruled Miller had a “full and fair” opportunity to litigate the issue, citing the fact that his criminal case lasted more than three years.
“We wade into uncharted waters in Indiana, but we reach safe harbor to conclude for the first time that plea agreements reflect a ‘full and fair opportunity to litigate,’ and thus collateral estoppel applies with equal force whether the prior criminal adjudication was based on a jury verdict or guilty plea,” the opinion says. “Both are simply two sides of the same coin: they each constitute final judgments.”
Considering whether applying collateral estoppel to Miller would be “otherwise unfair” because he entered a guilty but mentally ill plea, the majority concluded that while Miller’s mens rea wasn’t decided by a jury, he still “accepted the factual basis of his voluntary manslaughter conviction.”
The providers also met the burden of establishing Miller’s damages aren’t compensable, the majority ruled.
Miller’s motion opposing summary judgment “barely, if at all, addresses these damages,” the majority wrote, concluding Miller’s arguments about his pre-criminal-act damages were waived.
In a separate opinion, Rush wrote the providers didn’t carry their initial burden to show Miller’s pre-criminal-act damages aren’t compensable and thus aren’t entitled to summary judgment on the entirety of the complaint.
Rush also wrote Miller didn’t waive his argument on that issue because he raised it before the trial court and on appeal. Finding he waived his argument is “antithetical” to the court’s role in reviewing summary judgment to make sure no party is denied their day in court, she wrote.
The case is Zachary Miller v. Laxeshkumar Patel, M.D.; John Schiltz, M.D.; Benjamin Coplan, M.D.; Community Physicians of Indiana, Inc.; and Community Howard Regional Health, Inc., d/b/a Community Howard Behavioral Health, 22S-CT-371,
Please enable JavaScript to view this content.