## Facts

- During the 2011 Indiana legislative session, members of the Indiana House Democratic Caucus left the state to prevent a quorum and block a vote on pending legislation.
- The Indiana House imposed fines on absent legislators by motion as an internal disciplinary measure.
- The Speaker directed the Principal Clerk to submit payroll information to the Auditor of State to withhold the fines from the legislators’ pay.
- The affected legislators sued to recover withheld pay and to enjoin future withholding.
- Similar fines and withholdings occurred during the 2012 session, leading to a second suit that was consolidated with the first.
- The trial court held the imposition of fines was within the House’s exclusive authority and nonjusticiable, but concluded the collection of fines through wage withholding was judicially reviewable; it ordered repayment and enjoined future withholding.
- State officials appealed, and the Indiana Supreme Court accepted transfer.

## Issues

1. Whether separation of powers and the Indiana Constitution render nonjusticiable claims challenging the House’s internal decisions to discipline members by imposing fines for quorum-breaking absences.
2. Whether courts may review the House’s method of collecting fines (withholding legislative pay) even if the fine’s imposition and amount are constitutionally committed to the House.
3. Whether statutory wage-payment provisions can supply a basis for judicial relief that limits or controls a constitutionally assigned legislative disciplinary power.

## Decision

- The Indiana Supreme Court reversed the trial court.
- The Court held the claims challenging both the imposition and collection of the House fines were nonjusticiable.
- The Court ordered the case remanded with instructions to dismiss the complaints for lack of subject-matter jurisdiction/justiciability.

## Legal Principles

- When the Indiana Constitution expressly assigns a function to the legislative branch without qualification or limitation, challenges to that exercise of power are nonjusticiable, and separation of powers bars judicial review.
- The House’s constitutionally committed authority over internal proceedings and discipline includes not only deciding to impose sanctions on members but also implementing and enforcing those sanctions.
- Courts may not create a justiciable “collection” carve-out where reviewing enforcement would effectively control the effectiveness of a constitutionally authorized internal disciplinary measure.
- Statutory provisions cannot be used to authorize judicial oversight that would dilute or circumvent an exclusive constitutional allocation of authority to a coordinate branch.

## Conclusion

Because the Indiana Constitution commits member discipline and related enforcement choices to the House, the judiciary could not adjudicate disputes over fines imposed for quorum-breaking absences or the withholding of pay to collect those fines, requiring dismissal of the legislators’ suits as nonjusticiable.


Berry v. Crawford, 990 N.E.2d 410 (Ind. 2013)