INDIANAPOLIS (Legal Newsline) - An Indiana man who pled guilty to killing his grandfather can’t sue his doctors for letting him do it, the state’s highest court said, ruling for the first time on whether a criminal plea can block a subsequent civil lawsuit.
Zachary Miller was arrested for murder after his grandfather was found dead in 2017 While his criminal prosecution was pending in 2018, Miller filed a proposed complaint with the Indiana Department of Insurance, claiming because of negligence by medical providers, he “killed his grandma’s dog and killed his grandfather.”
He sued Community Physicians of Indiana and Community Howard Behavioral Health in March 2019. Then in August 2020, he pleaded “guilty but mentally ill” to voluntary manslaughter and was sentenced to 20 years.
In December 2020, the Indiana Medical Review Board found the evidence supported his claim doctors failed to meet the standard of care. His mother had become concerned about him hearing voices and threatening to strangle her “until her eyes popped out,” but he was released from the hospital three times, even after assaulting his grandfather and killing the family dog. The Indiana Supreme Court earlier ruled that his grandmother could sue Miller’s medical providers.
Miller wasn’t able to do the same, however. His providers moved for summary judgment, arguing Miller was barred from relitigating his responsibility for killing his grandfather. A trial judge dismissed the case and Miller appealed, saying he should be allowed to prove he was insane when he committed the crime and it wasn’t an intentional act.
The Indiana Court of Appeals reversed in 2022, citing another appeals court decision finding an exception to the general rule people can’t profit from their own crimes unless they were not responsible because of insanity. The Indiana Supreme Court reversed in a June 29 decision, however. It declined to endorse the “wrongful acts” doctrine, which prohibits people from trying to find others liable for their own criminal acts, although it said it might in future.
Instead, the court cited the doctrine of collateral estoppel, which prevents parties from re-litigating issues that have already been resolved through judgment. In this case, by pleading guilty, Miller established the mens rea or mental state required to find him solely responsible for any injuries arising from his crime.
“In essence, his medical malpractice claim turns on the theory that he was insane at the time of the killing,” the court said. ”But Miller’s mens rea was already established by his guilty but mentally ill plea, so he is attempting to relitigate the same issue.”
The court noted some might find its decision unfair, given Miller had pleaded guilty but mentally ill. It also noted that most criminal convictions come through plea bargains: In 2018, Indiana had 196,429 guilty pleas compared to 1,239 criminal jury trials. But criminal defendants make a cost-benefit assessment when they plead guilty, the court said, accepting judgment in exchange for what they perceive is lower risk of a harsh sentence.
“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 court concluded. “Both are simply two sides of the same coin: they each constitute final judgments.”