James E. Saylor v. State of Indiana
2017 Ind. App. LEXIS 293
| Ind. Ct. App. | 2017Background
- In 2007, James E. Saylor was convicted of multiple sexual-offense-related felonies and sentenced to an aggregate 138 years (including a habitual-offender enhancement); convictions were affirmed on direct appeal.
- In 2014 Saylor sought post-conviction relief; the post-conviction court denied relief but this Court later vacated only the habitual-offender adjudication and remanded that count for retrial (affirming other convictions).
- On September 13, 2016, Saylor filed a Petition for Declaratory Judgment claiming his initial arrest lacked probable cause and seeking an order declaring he was entitled to immediate release absent a valid showing of probable cause.
- The State moved for judgment on the pleadings under Indiana Trial Rule 12(C); the trial court granted the motion and dismissed Saylor’s declaratory petition.
- Saylor appealed, arguing the court erred by ruling without an evidentiary hearing and that his petition sought only a declaration of rights (not a collateral attack on his convictions).
- The Court of Appeals affirmed, holding (1) no evidentiary hearing was required on a 12(C) motion that relies solely on the pleadings, and (2) declaratory relief was improper because Saylor’s claim effectively sought to relitigate his convictions and/or would be advisory and thus nonjusticiable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in granting judgment on the pleadings without an evidentiary hearing | Saylor: court should have held an evidentiary hearing before granting judgment | State: 12(C) motion tests pleadings only; no hearing required | No error; pleadings-only motions admit well-pleaded facts and no hearing required |
| Whether declaratory relief was available to challenge probable-cause basis for arrest and obtain immediate release | Saylor: seeks declaration of rights re probable cause, not a collateral attack on conviction | State: petition improperly circumvents established post-conviction/remedy procedures; declaratory relief cannot substitute for available remedies | Denied; declaratory judgment inappropriate because it would either relitigate convictions or be advisory/nonjusticiable |
Key Cases Cited
- Veolia Water Indianapolis, LLC v. National Trust Ins. Co., 3 N.E.3d 1 (Ind. 2014) (standard for judgment on the pleadings/12(C) explained)
- Murray v. City of Lawrenceburg, 925 N.E.2d 728 (Ind. 2010) (pleadings-only dismissal standard discussed)
- KS&E Sports v. Runnels, 72 N.E.3d 892 (Ind. 2017) (treatment of 12(C) as 12(B)(6) where motion attacks sufficiency of pleading)
- Cobb v. Owen, 492 N.E.2d 19 (Ind. 1986) (no hearing required when motion addresses face of complaint and relies on pleadings)
- Midwest Psychological Center, Inc. v. Ind. Dept. of Admin., 959 N.E.2d 896 (Ind. Ct. App. 2011) (pleadings admissions and inference rules on motions to dismiss)
- Tramill v. Anonymous Healthcare Provider, 37 N.E.3d 553 (Ind. Ct. App. 2015) (purpose and limits of declaratory judgment relief)
- Volkswagenwerk A.G. v. Watson, 390 N.E.2d 1082 (Ind. Ct. App. 1979) (declaratory judgment not available where another adequate remedy exists)