useful framework in Indiana

2017The first category comprises cases where the statement or activity precipitating the underlying cause of action was ‘a person or entity in the public eye.’ The second category comprises cases where the statement or activity precipitating the underlying cause of action ‘involved conduct that could affect large numbers of people beyond the direct participants.’ And the third category comprises cases where the statement or activity precipitating the claim involved ‘a topic of widespread, public interest.’ Courts have adopted these categories as a useful framework for analyzing whether a statement

2017The first category comprises cases where the statement or activity precipitating the underlying cause of action [concerned] “a person or entity in the public eye.” The second category comprises- cases where the statement or activity precipitating the underlying cause of action “involved conduct that could [directly] affect [a] large number[ ] of people beyond the direct participants.” And the third category comprises cases where the statement or activity precipitating the claim involved “a topic of widespread, public interest.” Courts have adopted these categories as a useful framework for ana

2025The Tedlock court concluded that the offenses did not constitute a single episode of criminal conduct because “a complete account of each of [the] four offenses can be related without referring to details of another.” Id. at 276 . [23] Thereafter, the Tedlock test of determining whether a complete account of each offense could be related without reference to one another became a useful test for determining whether multiple offenses constituted a single episode of criminal conduct.

2025See, e.g., Smith v. State, 770 N.E.2d 290, 294 (Ind. 2002) (holding that defendant’s offenses for depositing six forged checks in his bank account over the course of three hours did not constitute a single episode of Court of Appeals of Indiana | Opinion 24A-CR-1824 | April 16, 2025 Page 11 of 17 criminal conduct because the Court could “recount each of the forgeries without referring to the other forgeries”); O’Connell, 742 N.E.2d at 951 (holding that defendant’s separate shootings over the course of two weeks could be “easily alleged without reference to the details of the others”). [24] In

2025See, e.g., Smith v. State, 770 N.E.2d 290, 294 (Ind. 2002) (holding that defendant’s offenses for depositing six forged checks in his bank account over the course of three hours did not constitute a single episode of Court of Appeals of Indiana | Opinion 24A-CR-1824 | April 16, 2025 Page 11 of 17 criminal conduct because the Court could “recount each of the forgeries without referring to the other forgeries”); O’Connell, 742 N.E.2d at 951 (holding that defendant’s separate shootings over the course of two weeks could be “easily alleged without reference to the details of the others”). [24] In

2024That said, between City of Gary and DePrizio, we find DePrizio generally more instructive given its command that exemptions under the UM/UIM Statute be “explicit.” In other words, DePrizio, though distinguishable, still offers a useful rule for us to analyze the degree to which an exemption—regardless of when it was passed—is explicit, thus allowing us to carry out the remedial purpose of the UM/UIM Statute in promoting recovery for innocent victims of automobile accidents. 705 N.E.2d at 459 .

2010We ultimately agreed with Fromme: "While we acknowledge that the three-step test has not always been applied to privileged information, we now conclude that it provides a useful framework for balancing the victim's interest in privacy with a defendant's constitutional rights." Crisis Connection, 930 N.E.2d at 1189-90 .

2010We held that defendants must meet the three-step test before obtaining an in camera review: "Requiring defendants to meet the three-step test before obtaining an in camera review creates the proper balance between a criminal defendant's constitutional rights and an alleged victim's need for privacy." Id. at 1190 .

1998As an aside, we commend the parties on their obvious cooperation which has allowed for meaningful judicial review while still addressing Clarian’s confidentiality concerns. .Ciarían has emphasized that we may not inquire into the adequacy of consideration exchanged in these contracts, citing IUF, 647 N.E.2d at 354 .