Berry v. Crawford

990 N.E.2d 410 (2013)

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Berry v. Crawford

Indiana Supreme Court
990 N.E.2d 410 (2013)

DC

Facts

To block votes on impending legislation, members of the Indiana House of Representatives’ Democratic Caucus (the absent legislators) (plaintiff) left the state to prevent the House from obtaining the necessary quorum to pass legislation during the 2011 and 2012 legislative sessions. The House’s Republican Caucus imposed fines on the absent legislators, and the speaker of the House directed the fines to be withheld from the absent legislators’ pay after both incidents. The absent members sued state officials (defendant) after fines were imposed in 2011 and again in 2012. The trial court found that the House’s exclusive constitutional authority to compel member attendance and set disciplinary fines could not be judicially reviewed, but the court could interpret and enforce Indiana statutory law. The trial court found that the seizure of the absent legislators’ wages violated Indiana’s wage-payment statutes and ordered the return of withheld wages. The state officials appealed.

Rule of Law

Issue

Holding and Reasoning (Dickson, C.J.)

Dissent (Rucker, J.)

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