In the meantime, Miller filed a proposed complaint for damages with the Indiana Department of Insurance, alleging Providers had committed medical malpractice in their treatment of him which resulted in him suffering mental trauma, emotional distress, and loss of his freedom. The Medical Review Panel found that Providers failed to comply with the appropriate standard of care and that this failure was a factor in the resulting damages alleged by Miller.
Miller filed a complaint for damages against Providers in the trial court. Providers subsequently filed their motion for summary judgment, to which Miller responded. Following a hearing, the court granted summary judgment to Providers. Thereafter, Miller’s motion to reconsider was denied, and Miller appealed.
The Court of Appeals of Indiana (“Indiana Appellate Court”) stated in its opinion filed on May 24, 2022 that collateral estoppel did not apply to preclude Miller’s complaint for damages, explaining: “In light of the evidence of both the State’s and the trial court’s awareness concerning the role the lack of mental health treatment had in Miller’s actions and the consideration given by the trial court to the mitigating evidence of substantial grounds that excused or justified the crime, we conclude Miller did not have a full and fair opportunity to litigate the issue of his criminal responsibility in the criminal case. Additionally, under the circumstances presented here it would be otherwise unfair to apply collateral estoppel to preclude Miller from attempting to rebut the inference of his sanity established by his plea of guilty but mentally ill. Consequently, Providers, whose burden it was to show they were entitled to the use of collateral estoppel, have failed, and the trial court’s application of collateral estoppel to preclude Miller’s civil claim was in error.”
The Indiana Appellate Court further stated: “this Court has stated that the public policy of precluding a convicted individual from imposing upon others civil liability for his criminal conduct is not justified and should not operate to preclude a civil action when the convicted individual-plaintiff is not responsible for the act in question. Rimert, 680 N.E.2d at 874-75. Accordingly, our public policy should not preclude Miller from attempting to rebut the facts as established by his criminal conviction and prove that he was criminally insane at the time of the killing and thus not responsible for the act.”
Source Miller v. Patel, M.D., Court of Appeals Case No. 21A-CT-2500.
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