Justia Civil Procedure Opinion Summaries

Bernadette O’Malley purchased a used 2007 Dodge Caliber from Valpo Motors, Inc. in late 2019. Valpo provided O’Malley with a Buyers Guide stating the car was sold “AS IS” and a Sales Agreement that disclaimed all warranties unless a written warranty or service contract was extended within 90 days. O’Malley also purchased a Service Contract, which was noted in the Buyers Guide. The car broke down a month later, and a repair shop deemed it not worth repairing due to extensive mechanical issues. O’Malley’s son-in-law, Glenn Thomas, took the car to the shop. After Valpo refused to arbitrate, O’Malley sued for breach of implied warranty of merchantability under the Magnuson-Moss Warranty Act (MMWA). O’Malley passed away during the proceedings, and Thomas continued the case as the personal representative of her estate.The Porter Superior Court granted summary judgment for Valpo Motors, and the Indiana Court of Appeals affirmed, holding that the Buyers Guide’s disclaimer of all warranties controlled over any contrary provisions in the Sales Agreement. The appellate court rejected Thomas’s argument that the handwritten note on the Buyers Guide negated the warranty disclaimer. Judge Felix dissented, arguing that the Sales Agreement’s specific terms should trump the Buyers Guide’s general terms and that there was a genuine issue of material fact regarding Valpo’s opportunity to cure the breach.The Indiana Supreme Court reviewed the case and held that Valpo did not effectively disclaim the implied warranty of merchantability due to ambiguities in the Buyers Guide. The court found that fact issues remained regarding whether Valpo had a reasonable opportunity to cure the defects. The court vacated the summary judgment for Valpo, directed the trial court to enter partial summary judgment for Thomas on the warranty-disclaimer issue, and remanded for further proceedings to determine if Valpo had a reasonable opportunity to cure. If Thomas prevails, the trial court is to assess damages and reasonable attorney’s fees. View "Thomas v. Valpo Motors Inc." on Justia Law

In January 2023, J.F., a 39-year-old woman with a history of substance abuse, began experiencing severe delusions and paranoia, believing her parents wanted to kill her and her children. After a series of incidents, including living in her car and being admitted to the St. Vincent Stress Center, J.F. was temporarily committed by a trial court for up to ninety days due to her mental illness and inability to keep herself safe.J.F. appealed the commitment, arguing insufficient evidence supported the order. The Court of Appeals dismissed her appeal as moot, stating it did not present a novel issue or particularized harmful consequence. J.F. then petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court held that temporary commitment appeals are not moot upon expiration unless the appellee proves no collateral consequences exist. The court emphasized the significant liberty interests and lifelong collateral consequences involved in such commitments, warranting appellate review. The court found sufficient evidence to support J.F.'s commitment, noting her impaired reasoning, inability to function independently, and the danger she posed to herself. Consequently, the court affirmed the trial court's temporary commitment order. View "In re Commitment of J.F." on Justia Law

The Hoagland Family Limited Partnership and its partners have been involved in a legal dispute with the Town of Clear Lake regarding a sewage hookup since 2010. This ongoing litigation is under case number 76C01-1006-PL-425 in the Steuben Circuit Court. In 2023, Hoagland filed a new complaint in the Steuben Superior Court (case number 76D01-2305-PL-237) against the Town and various associated parties. The claims in this new case were based on the same facts and circumstances as the ongoing case. Consequently, the superior court dismissed the new complaint under Trial Rule 12(B)(8), which addresses the issue of the same action pending in another state court.The Steuben Superior Court dismissed the new case with prejudice, meaning that Hoagland would be precluded from bringing the same claims again. Hoagland did not contest the dismissal itself but argued against the dismissal being with prejudice. The Indiana Court of Appeals affirmed the superior court's decision.The Indiana Supreme Court reviewed the case and found that the superior court erred in dismissing the case with prejudice. The Supreme Court noted that a dismissal with prejudice is akin to a judgment on the merits and precludes relitigation of the claims. The court emphasized that Hoagland should not be prematurely denied the opportunity to litigate its claims. Therefore, the Indiana Supreme Court vacated the Court of Appeals' opinion and remanded the case to the superior court with instructions to dismiss the case without prejudice. This allows Hoagland the possibility to pursue its claims in the ongoing litigation in the Steuben Circuit Court. View "Hoagland Family Limited Partnership v. Town of Clear Lake" on Justia Law

An Indiana trust beneficiary sued the trustee, an Indiana bank, in an Indiana trial court over the disposal of trust property. The trust, which holds Illinois real estate, is governed by Illinois law and includes mostly Illinois beneficiaries. The trial court dismissed the action for lack of subject-matter jurisdiction, questioning the appropriateness of resolving Illinois-centered issues in Indiana.The Vigo Superior Court dismissed the case, agreeing with the trustee that Indiana lacked subject-matter jurisdiction because the trust was administered in Illinois. The Indiana Court of Appeals reversed this decision, ruling that the trial court had jurisdiction over the Indiana suit despite the trust's Illinois connections. The appellate court distinguished this case from In re Alford Trust, which held that Indiana courts lack jurisdiction over trusts administered exclusively in another state.The Indiana Supreme Court reviewed the case and held that the trial court has subject-matter jurisdiction over the dispute. The court clarified that Indiana superior courts have broad civil jurisdiction, including over trust disputes, and that venue provisions do not affect jurisdiction. The court disapproved of the Alford Trust decision for conflating jurisdiction with prudential concerns like venue and choice of law. The court noted that while the trial court has jurisdiction, it may still dismiss the case under doctrines like comity or forum non conveniens if appropriate. The Indiana Supreme Court reversed the trial court's dismissal and remanded the case for further proceedings. View "Tingley v. First Financial Bank" on Justia Law

Gerard A. Kirsch, a member of Calvary Temple Church of Evansville, Inc., was injured while building a storage barn on the church's property. Kirsch fell from a ladder and sustained a severe arm injury. He sued the church, alleging negligence for failing to provide safe equipment and proper supervision.The Vanderburgh Superior Court denied the church's motion for summary judgment, which argued that Indiana Code section 34-31-7-2 limited the church's liability. The court held that a jury must decide if the church breached any duty to Kirsch. The Indiana Court of Appeals affirmed, interpreting the statute narrowly to apply only to parts of the premises used primarily for worship services, thus allowing Kirsch's claim to proceed.The Indiana Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that the term "premises" in Indiana Code section 34-31-7-2 includes the entire parcel of land owned by the church, not just the areas used primarily for worship services. Since the church's entire property is used primarily for worship services, the statute applies, limiting the church's liability to warning of hidden dangers and refraining from intentional harm. Kirsch admitted the church breached neither duty, leading the court to grant summary judgment in favor of the church. View "Calvary Temple Church of Evansville, Inc. v. Kirsch" on Justia Law

A motorist struck and injured a pedestrian during rush hour. The motorist claimed the pedestrian stepped out from behind a large truck, obstructing her view. Witnesses and investigating officers corroborated the motorist's account, finding no evidence of speeding, reckless driving, or distraction. The pedestrian sued the motorist and her insurer for negligence, and the motorist raised a contributory-negligence defense.The Hamilton Superior Court initially granted the pedestrian's motion to compel the motorist to produce her iPhone for inspection, limited to the hour surrounding the accident. However, the court reversed its decision upon reconsideration, citing significant privacy concerns and lack of evidence suggesting the motorist was using her phone at the time. The court also granted a motion in limine to exclude any discussion of the phone inspection at trial. A jury found the pedestrian 90% at fault, barring recovery under Indiana's contributory-fault standard. The Indiana Court of Appeals affirmed, holding that the burden of the proposed phone inspection outweighed its likely benefit given the motorist's privacy concerns.The Indiana Supreme Court affirmed the lower court's decision, holding that the pedestrian's discovery request lacked necessary evidentiary support and was overly broad. The court emphasized that privacy concerns are not a per se bar to discovery but must be balanced against the need for information. The court concluded that the trial court did not abuse its discretion in denying the motion to compel, as the pedestrian failed to show that the benefit of inspecting the motorist's phone outweighed her privacy interests. View "Jennings v. Smiley" on Justia Law

Automotive Finance Corporation (AFC) extended a loan to Monmars Automotive Group LLC, which was guaranteed by Meng Liu, her then-husband Ning Ao, and Liu’s friend Xiaoqiao Yang. After Monmars defaulted, AFC sued to recover the debt. Liu, representing herself, filed unsworn letters claiming she did not sign the loan agreement. The trial court granted summary judgment for AFC. Ao later admitted in an unsworn letter to forging Liu’s and Yang’s signatures, but Liu did not file a motion to correct error or appeal properly.The Marion Superior Court set aside the judgment based on fraud under Trial Rule 60(B)(3) after Liu, now represented by counsel, presented Ao’s testimony about the forgery. AFC appealed, and the Indiana Court of Appeals issued conflicting opinions in related cases. In Liu’s case, the court affirmed the trial court’s decision, but in Yang’s case, it reversed.The Indiana Supreme Court reviewed the case and held that the trial court abused its discretion in granting relief under Trial Rule 60(B)(3). The court found that Liu could have raised the fraud issue in a timely motion to correct error or on appeal. Additionally, there was no evidence that the alleged fraud prejudiced Liu’s ability to present her case. The court emphasized the importance of finality in judgments and the need for litigants, including those representing themselves, to comply with procedural requirements.The Indiana Supreme Court reversed the trial court’s decision and remanded the case for reinstatement of summary judgment in favor of AFC. View "Automotive Finance Corporation v. Liu" on Justia Law

In late 2019, a hospital sent letters to over a thousand patients, including Linda Gierek, informing them of potential exposure to infectious diseases due to a technician's failure to fully sterilize surgical instruments. Gierek filed a class-action complaint against the hospital, asserting claims of negligent infliction of emotional distress, negligence, and medical malpractice. She sought class certification for similarly situated patients and their spouses. The trial court consolidated Gierek’s action with a similar class-action claim filed by Cheyanne Bennett.The Indiana Patient’s Compensation Fund intervened, arguing that the claims sounded in ordinary negligence and thus the Medical Malpractice Act (MMA) did not apply. The hospital argued the opposite. The trial court ruled in favor of the hospital, stating the MMA applied, and denied the motion for class certification, citing lack of subject-matter jurisdiction while a proposed complaint was pending before a medical-review panel. On appeal, the Court of Appeals affirmed the MMA’s applicability but reversed the trial court’s decision on class certification jurisdiction.The Indiana Supreme Court reviewed the case and held that the MMA covers all claims for medical malpractice, not limited to bodily injury or death. The court also held that class certification is a proper preliminary determination under the MMA. The court affirmed in part, reversed in part, and remanded the case for the trial court to consider the plaintiffs’ motion for class certification. View "Gierek v. Anonymous 1" on Justia Law

AMW Investments, Inc. and Midwest Entertainment Ventures, Inc. (collectively, AMW) owned and operated an adult-entertainment venue called Theatre X. The Town of Clarksville revoked AMW’s adult-entertainment license in early 2019 due to violations of local ordinances against lewd conduct. AMW sought judicial review of the revocation in the Clark Circuit Court, which led to the Town filing counterclaims and seeking a preliminary injunction to bar AMW from operating Theatre X. The trial court issued the injunction and deferred ruling on fines pending AMW’s appeal of the injunction.The Clark Circuit Court ordered AMW to respond to the Town’s discovery requests, but AMW only objected on jurisdictional grounds, claiming the trial court lacked jurisdiction during the appeal. The trial court found AMW’s objections inexcusable and ordered compliance. AMW continued to object and withhold documents, leading the trial court to find AMW in contempt and impose a $30,000 sanction. AMW appealed the sanction, and the Indiana Court of Appeals reversed, holding that AMW’s objections were not waived.The Indiana Supreme Court reviewed the case and held that AMW’s objections were untimely and thus waived. The Court affirmed the trial court’s discovery order and sanction, stating that the trial court did not lose jurisdiction during the appeal and no stay was issued. The Court emphasized that untimely objections are presumptively waived under the trial rules, and the trial court did not abuse its discretion in refusing to excuse the waiver or in sanctioning AMW for non-compliance. The case was remanded for further proceedings consistent with the opinion. View "AMW Investments Inc. v. The Town of Clarksville" on Justia Law

R.L., a sheriff’s deputy, was charged with driving while intoxicated, but the charges were later dropped. The Indiana Law Enforcement Training Board initiated proceedings to revoke R.L.'s basic-training certificate, which is necessary for his employment as an officer. R.L. sought and obtained a court declaration and injunction preventing the board from disciplining him before the board issued a final decision.The Martin Circuit Court granted R.L.'s request for declaratory and injunctive relief, barring the board from using facts from R.L.'s expunged arrest to revoke his certificate. The board intervened and moved to vacate the order, arguing procedural errors and lack of merit. The trial court vacated its initial order but issued a second similar order. The board appealed, and the Indiana Court of Appeals reversed the trial court's decision, allowing the board to consider independent evidence of the facts underlying the expunged arrest records.The Indiana Supreme Court reviewed the case and held that the trial court erred in granting R.L.'s request for declaratory and injunctive relief. The court emphasized that R.L. must follow the Administrative Orders and Procedures Act (AOPA) to challenge the board's decisions and that he failed to exhaust administrative remedies before seeking judicial intervention. The court reversed the trial court's judgment and remanded with instructions to dismiss R.L.'s declaratory-judgment action, reinforcing the necessity of exhausting administrative remedies before seeking judicial review. View "Indiana Law Enforcement Training Board v. R L" on Justia Law