Taliyah Brooks v. USA Track & Field, Inc.

Summary

The Indiana Supreme Court held that a party may not amend a complaint after final judgment unless the judgment is first vacated or set aside under Indiana Trial Rules 59 or 60. The court affirmed denial of Taliyah Brooks’s motion to amend her declaratory-judgment complaint to add tort claims against USA Track & Field, Inc., and clarified that Indiana Trial Rule 15(A) does not apply after final judgment. Justice Goff dissented, concluding that the trial court improperly entered summary judgment and that the agreement’s indemnification provision violated public policy.

Holdings

1. A party may not amend a complaint after final judgment has been entered unless the judgment is first vacated or set aside under Indiana Trial Rule 59 or Trial Rule 60.
2. The trial court correctly denied Brooks's motion to amend because final judgment had already been entered and the court had no discretion to grant the motion.
3. The Court of Appeals' treatment and analysis of the summary-judgment orders is summarily affirmed.

Questions Presented

1. Whether a party may amend a complaint under Indiana Trial Rule 15(A) after the trial court has entered final judgment.
2. Whether the trial court erred in denying Brooks's motion to amend her complaint to add tort claims after entering summary judgment for USATF.
3. Whether the trial court's summary-judgment orders should be affirmed.

Disposition

affirmed