Zachary Miller v. Laxeshkumar Patel, M.D.

Summary

The Indiana Supreme Court affirmed summary judgment for Miller’s mental-health providers, holding that a knowingly, intelligently, and voluntarily entered guilty plea has the same collateral-estoppel effect as a conviction after trial. Because Miller’s plea necessarily established his legal responsibility and mens rea for voluntary manslaughter, he could not relitigate those issues in his malpractice action. The court also held that any claim for damages predating the criminal act was waived on appeal.