While a trial court can take judicial notice of reasonable attorney’s fees in routine cases involving relatively small amounts, the trial court abused its discretion when it awarded appellate attorney’s fees in a reduced hourly amount with no evidence to support the reduced rate.
Civil
Abbott v. State, 19A-PL-1635, __ N.E.3d __ (Ind. Ct. App., Feb. 15, 2021).
In a civil forfeiture action, the res may be used for defense related expenses.
Cooper’s Hawk Indianapolis, LLC v. Ray, No. 21S-CT-56, __ N.E.3d __ (Ind., Feb. 9, 2021).
A belated notice of appeal needs to do more than restate the grounds for granting a discretionary appeal; an extraordinary compelling reason to restore the forfeited appeal must be stated.
Hartman v. BigInch Fabricators & Construction Holding Co., Inc., No. 20S-PL-00618, __ N.E.3d __ (Ind., Jan. 28, 2021).
Parties’ freedom to contract may permit “minority” and “marketability” discounts for valuing corporate shares even for shares in a closed-market transaction.
Doe v. Carmel Operator, LLC, No. 21S-CT-15, __ N.E.3d __ (Ind., Jan. 15, 2020).
Equitable estoppel can be applied only if three elements are shown: lack of knowledge, reliance, and prejudicial effect. The Court declines to adopt alternative theories for equitable estoppel.