intermediate standard (Indiana) · Go Syfert
← Indiana issues

intermediate standard in Indiana

39 Indiana opinions name it 2 courts 1888–2026 10 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
In the Matter of the Civil Commitment of T.D. v. Eskenazi Health Midtown Community Mental Health Centergreen
indctapp · 2015 · cited in 18 Indiana opinions naming this issue, 2016–2026
2 sentences

2026T.D. v. Eskenazi Health Midtown Cmty. Mental Health Ctr., 40 N.E.3d 507, 510 (Ind. Ct. App. 2015).

2024Clear and convincing evidence is “an intermediate standard of proof greater than a preponderance of the evidence and less than proof beyond a reasonable doubt.” T.D. v. Eskenazi Health Midtown Cmty. Mental Health Ctr., 40 N.E.3d 507, 510 (Ind. Ct. App. 2015).

1718
JCC v. Stategreen
ind · 2008 · cited in 4 Indiana opinions naming this issue, 2012–2026
2 sentences

2026Constructive fraud can occur when there is a “breach of a duty arising from a confidential or fiduciary relation.” Id. at 280 (quoting Hall, 351 N.E.2d at 38 ). 3The clear-and-convincing-evidence standard is an intermediate standard of proof used in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals.” J.C.C. v. State, 897 N.E.2d 931, 935 (Ind. 2008) (quoting Est. of Reasor v. Putnam Cnty., 635 N.E.2d 153 , 159–60

2024As our Supreme Court explained, the “clear and convincing” standard is an intermediate standard of proof employed in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals[.]” In re G.Y., 904 N.E.2d 1257 , 1260 n.1 (Ind. 2009) (quoting J.C.C. v. State, 897 N.E.2d 931, 934 (Ind. 2008)). [26] Here, the trial court entered sua sponte findings on the constructive trust issue.

44
In the Matter of the Civil Commitment of B.J. v. Eskenazi Hospital/Midtown CMHC (mem. dec.)green
indctapp · 2016 · cited in 2 Indiana opinions naming this issue, 2023–2024
2 sentences

2024“In order to be clear and convincing, the existence of a fact Court of Appeals of Indiana | Opinion 23A-CR-1489 | February 9, 2024 Page 9 of 14 must be highly probable.” Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034, 1038 (Ind. Ct. App. 2016).

2023The clear-and-convincing-evidence standard is “an intermediate standard of proof greater than a preponderance of the evidence and less than proof beyond a reasonable doubt.” B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034, 1038 (Ind. Ct. App. 2016).

22
Santosky v. Kramergreen
scotus · 1982 · cited in 2 Indiana opinions naming this issue, 1983–2012
2 sentences

2012We further observe that utilization of this clear and convincing standard of proof comports with the United States Supreme Court’s mandate that an intermediate standard of proof be applied when an individual’s interests at stake in a particular state proceeding are both “particularly important” and “more substantial than the mere loss of money.” See Santosky v. Kramer, 455 U.S. 745, 756 (1982).

1983Santosky v. Kramer, 455 U.S. at 756 , 102 S.Ct. at 1395 .

12
Lazarus Department Store v. Sutherlingreen
indctapp · 1989 · cited in 1 Indiana opinions naming this issue, 2015–2015
1 sentence

2015Lazarus Dep’t Store v. Sutherlin, 544 N.E.2d 513, 527 (Ind.Ct.App.1989), reh’g denied, trans. denied.

11
Term. of Parent-Child Rel. of I.A. J.H. v. IDCSgreen
ind · 2010 · cited in 1 Indiana opinions naming this issue, 2012–2012
1 sentence

2012Regarding our appellate standard of review, the Indiana Supreme Court has repeatedly stated that appellate courts must give ‘“due regard” to the trial court’s unique opportunity to judge the credibility of the witnesses.” See In re I.A., 934 N.E.2d 1127, 1132 (Ind. 2010).

11
Romine v. Gaglegreen
indctapp · 2003 · cited in 1 Indiana opinions naming this issue, 2009–2009
1 sentence

2009Clear and convincing evidence "indicatles] that the thing to be proved is highly probable or reasonably certain." Black's Law Dictionary 596 (8th ed.2004); see Romine v. Gagle, 782 N.E.2d 369, 384 (Ind.Ct.App.2003) ("Clear and convincing evidence" is "an intermediate standard of proof greater than a preponderance of the evidence and less than proof beyond a reasonable doubt and requires the existence of a fact to be highly probable").

11
Erie Insurance Co. v. Hickman Ex Rel. Smithgreen
ind · 1992 · cited in 1 Indiana opinions naming this issue, 2003–2003
1 sentence

2003Co. v. Hickman by Smith, 605 N.E.2d 161, 162 (Ind.1992).

11
Doe v. Methodist Hospitalgreen
ind · 1997 · cited in 1 Indiana opinions naming this issue, 1999–1999
2 sentences

1999New York Court of Appeals in Chapadeau v. Utica Observer-Dispatch, Inc., 38 N.Y.2d 196 , 379 N.Y.S.2d 61 , 341 N.E.2d 569, 570-71 (N.Y.1975), adopted an intermediate standard of "gross irresponsibility." SMOLLA, supra, ž 3.12. [14] See also Doe v. Methodist Hosp., 690 N.E.2d 681, 695 (Ind.1997) (Dickson, J., concurring in result with separate opinion, in which Sullivan, J., concurred) ("The Indiana Constitution provides express recognition of an individual's interest in reputation and accords it specific protection."). [15] This statement is well-supported in Anglo-American and Indiana law.

1999See also Doe v. Methodist Hosp., 690 N.E.2d 681, 695 (Ind. 1997) (Dickson, J., concurring in result with separate opinion, in which Sullivan, J., concurred) ("The Indiana Constitution provides express recognition of an individual’s interest in reputation and accords it specific protection."). .

11
Chapadeau v. Utica Observer-Dispatch, Inc.green
ny · 1975 · cited in 1 Indiana opinions naming this issue, 1999–1999
2 sentences

1999New York Court of Appeals in Chapadeau v. Utica Observer-Dispatch, Inc., 38 N.Y.2d 196 , 379 N.Y.S.2d 61 , 341 N.E.2d 569, 570-71 (N.Y.1975), adopted an intermediate standard of "gross irresponsibility.” Smolla, supra, § 3.12. .

1999New York Court of Appeals in Chapadeau v. Utica Observer-Dispatch, Inc., 38 N.Y.2d 196 , 379 N.Y.S.2d 61 , 341 N.E.2d 569, 570-71 (N.Y.1975), adopted an intermediate standard of "gross irresponsibility.” Smolla, supra, § 3.12. .

11
Mercer - Fraser Co. v. Industrial Accident Commissiongreen
cal · 1953 · cited in 1 Indiana opinions naming this issue, 1987–1987
2 sentences

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Beazley v. Torto-rich (La.1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Beazley v. Torto-rich (La.1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

11
Serna v. Statewide Contractors, Inc.green
arizctapp · 1967 · cited in 1 Indiana opinions naming this issue, 1987–1987
2 sentences

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Bazley v. Tortorich (La. 1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Beazley v. Torto-rich (La.1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

11
In Re the Suspension of the Right to Practice Law of Palmergreen
nc · 1979 · cited in 1 Indiana opinions naming this issue, 1983–1983
1 sentence

1983See, Matter of Palmer, (1979) 296 N.C. 688 , 252 S.E.2d 784 and cases cited therein.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Mills v. Habluetzel green
scotus · 1982
2 sentences

1987James argues under the intermediate standard of review as set out in Pickett v. Brown (1983), 462 U.S. 1 , 103 S.Ct. 2199 , 76 L.Ed.2d 372 ; and Mills v. Habluetzel (1982), 456 U.S. 91 , 102 S.Ct. 1549 , 71 L.Ed.2d 770 .

1987James argues under the intermediate standard of review as set out in Pickett v. Brown (1983), 462 U.S. 1 , 103 S.Ct. 2199 , 76 L.Ed.2d 372 ; and Mills v. Habluetzel (1982), 456 U.S. 91 , 102 S.Ct. 1549 , 71 L.Ed.2d 770 .

21987–1987
Pickett v. Brown green
scotus · 1983
2 sentences

1987James argues under the intermediate standard of review as set out in Pickett v. Brown (1983), 462 U.S. 1 , 103 S.Ct. 2199 , 76 L.Ed.2d 372 ; and Mills v. Habluetzel (1982), 456 U.S. 91 , 102 S.Ct. 1549 , 71 L.Ed.2d 770 .

1987James argues under the intermediate standard of review as set out in Pickett v. Brown (1983), 462 U.S. 1 , 103 S.Ct. 2199 , 76 L.Ed.2d 372 ; and Mills v. Habluetzel (1982), 456 U.S. 91 , 102 S.Ct. 1549 , 71 L.Ed.2d 770 .

21987–1987
Kalwitz v. Estate of Kalwitz green
indctapp · 2005
1 sentence

2026Constructive fraud can occur when there is a “breach of a duty arising from a confidential or fiduciary relation.” Id. at 280 (quoting Hall, 351 N.E.2d at 38 ). 3The clear-and-convincing-evidence standard is an intermediate standard of proof used in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals.” J.C.C. v. State, 897 N.E.2d 931, 935 (Ind. 2008) (quoting Est. of Reasor v. Putnam Cnty., 635 N.E.2d 153 , 159–60

12026–2026
Hall v. Indiana Department of State Revenue green
indctapp · 1976
1 sentence

2026Constructive fraud can occur when there is a “breach of a duty arising from a confidential or fiduciary relation.” Id. at 280 (quoting Hall, 351 N.E.2d at 38 ). 3The clear-and-convincing-evidence standard is an intermediate standard of proof used in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals.” J.C.C. v. State, 897 N.E.2d 931, 935 (Ind. 2008) (quoting Est. of Reasor v. Putnam Cnty., 635 N.E.2d 153 , 159–60

12026–2026
Estate of Reasor v. Putnam County green
ind · 1994
1 sentence

2026Constructive fraud can occur when there is a “breach of a duty arising from a confidential or fiduciary relation.” Id. at 280 (quoting Hall, 351 N.E.2d at 38 ). 3The clear-and-convincing-evidence standard is an intermediate standard of proof used in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals.” J.C.C. v. State, 897 N.E.2d 931, 935 (Ind. 2008) (quoting Est. of Reasor v. Putnam Cnty., 635 N.E.2d 153 , 159–60

12026–2026
In Re GY green
ind · 2009
1 sentence

2024As our Supreme Court explained, the “clear and convincing” standard is an intermediate standard of proof employed in cases “where the wisdom of experience has demonstrated the need for greater certainty, and where this high standard is required to sustain claims [that] have serious social consequences or harsh or far reaching effects on individuals[.]” In re G.Y., 904 N.E.2d 1257 , 1260 n.1 (Ind. 2009) (quoting J.C.C. v. State, 897 N.E.2d 931, 934 (Ind. 2008)). [26] Here, the trial court entered sua sponte findings on the constructive trust issue.

12024–2024
An-Hung Yao and Yu-Ting Lin v. State of Indiana green
ind · 2012
1 sentence

2015An-Hung Yao v. State, 975 N.E.2d 1273 (Ind.2012). [12] The clear and convincing standard is an intermediate standard of proof that[] lies between a preponderance of the evidence and beyond a reasonable doubt which is required to find [a defendant] guilty in criminal prosecutions.

12015–2015
Woodby v. Immigration & Naturalization Service green
scotus · 1966
2 sentences

1993The intermediate standard, which usually employs some combination of the words "clear," "cogent," "unequivocal," and "convincing," is less commonly used, but nonetheless "is no stranger to the civil law." Woodby v. INS, 385 U.S. 276, 285 , 87 S.Ct. 483, 488 , 17 L.Ed.2d 362 (1966)... .

1993In re Winship, supra. The intermediate standard, which usually employs some combination of the words "clear," "cogent," "unequivocal," and "convincing," is less commonly used, but nonetheless "is no stranger to the civil law." - Woodby v. INS, 885 U.S. 276 , 285, 87 S.Ct. 483, 488 , 17 LEd.2d 862 (1966)....

11993–1993
Orkin Exterminating Co., Inc. v. Traina green
ind · 1986
1 sentence

1988Notwithstanding observations contained in Traina dicta, 486 N.E.2d at 1024 , we find that the above instructions were complete and sufficient to advise the jury with respect to punitive damages, and required no further elaboration.

11988–1988
Bazley v. Tortorich green
la · 1981
2 sentences

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Bazley v. Tortorich (La. 1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

1987See Serna v. Statewide Contractors (1967), 6 Ariz. 12, 15 , 429 P.2d 504, 508 (the most stringent standard); Beazley v. Torto-rich (La.1981), 397 So.2d 475 (the intermediate standard adopting the definition of intent contained in Restatement (Second) of Torts Section 8A (1965)); and finally, Mercer Fraser Co. v. Industrial Accident Comm'n. (1953), 40 Cal.2d 102, 120 , 251 P.2d 955, 964 (the most liberal standard).

11987–1987
Mathews v. Eldridge green
scotus · 1976
2 sentences

1983Santosky v. Kramer, supra, involved the termination of parental rights; applying the factors set forth in Mathews v. Eldridge (1976), 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 , a majority of the United States Supreme Court concluded that a "fair preponderance of the evidence standard" in such proceeding was inconsistent with due process. 1 In the course of this analysis, the Court noted that an intermediate standard of proof (clear and convincing) 2 has been mandated where the individual interests at stake in a particular state proceeding are both "particularly important" and "more substant

1983Santosky v. Kramer, supra, involved the termination of parental rights; applying the factors set forth in Mathews v. Eldridge (1976), 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 , a majority of the United States Supreme Court concluded that a "fair preponderance of the evidence standard" in such proceeding was inconsistent with due process. 1 In the course of this analysis, the Court noted that an intermediate standard of proof (clear and convincing) 2 has been mandated where the individual interests at stake in a particular state proceeding are both "particularly important" and "more substant

11983–1983
Putt v. Putt neutral
ind · 1897
1 sentence

1908Putt v. Putt (1897), 149 Ind. 30 .

11908–1908
Douthit v. Douthit green
ind · 1892
1 sentence

1902If, therefore, it' appears from the findings in so far as they were based upon issues that the appellant had the burden of maintaining, that appellant is not entitled to recover, then it is our duty to disregard an intermediate error in the ruling upon a demurrer to an affirmative pleading of appellee, .because it would then be apparent that the ruling was not influential in the attainment of a proper result. §670 Burns 1901; Douthit v. Douthit, 133 Ind. 26 ; Elliott App. Proc., §635.

11902–1902
Krug v. Davis neutral
ind · 1885
1 sentence

1888Krug v. Davis, 101 Ind. 75 ; Bothwell v. Millikan, 104 Ind. 162 .

11888–1888
Bothwell v. Millikan green
ind · 1885
1 sentence

1888Krug v. Davis, 101 Ind. 75 ; Bothwell v. Millikan, 104 Ind. 162 .

11888–1888

Statutes the citing opinions construe

IN § Ind. Code § 12-26-2-5 (16) IN § Ind. Code § 12-7-2-96 (13) IN § Ind. Code § 12-7-2-53 (3) IN § Ind. Code § 31-19-10-1 (3) IN § Ind. Code § 31-19-11-1 (3) IN § Ind. Code § 31-19-9-1 (3) IN § Ind. Code § 31-19-9-8 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 532 (1981–2026) PA 54 (1978–2025) CA 45 (1978–2026) UT 45 (1930–2025) IL 45 (1986–2024) LA 43 (1920–2020) ND 39 (1974–2018) IN 39 (1888–2026) WA 28 (1917–2026) OH 28 (1992–2021) GA 24 (1993–2026) DE 23 (1980–2026) CT 22 (1985–2025) KS 22 (1987–2024) CO 21 (1982–2003) MD 18 (1981–2022) NC 17 (1984–2025) NJ 16 (1972–2017) FL 14 (1963–2018) ID 14 (1982–1999) NY 13 (1949–2025) OK 11 (1980–2024) HI 10 (1996–2025) TN 9 (1959–2010) WI 8 (1996–2020) OR 8 (1983–2020) NM 7 (1988–2023) AZ 7 (1988–2011) ME 6 (1984–2015) DC 6 (1978–1997) IA 6 (2009–2023) SC 5 (1996–2022) MI 5 (1978–2015) MO 4 (1980–2016) KY 3 (1954–2010) WV 3 (1995–2024) VA 3 (1995–2004) MA 3 (1975–1990) VI 2 (2013–2026) MN 2 (1987–2011) SD 2 (1991–1993) MS 2 (1984–2013) MT 2 (1995–2005) NV 2 (2020–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check