Loparex, LLC v. MPI Release Technologies, LLC

954 N.E.2d 449 (Ind. 2011) · Supreme Court of Indiana · September 30, 2011 · No. 94S00-1109-CQ-546

Summary

The Indiana Supreme Court accepted three certified questions from the U.S. District Court for the Southern District of Indiana concerning Indiana Code section 22-5-3-2, including claims by voluntarily departing employees, recovery of attorney fees, and unsuccessful trade-secret litigation. The order establishes briefing, appendix, filing, service, appearance, and related procedural requirements for the certified-question proceeding.

Court
Supreme Court of Indiana
Jurisdiction
Indiana
Decision date
September 30, 2011
Docket number
94S00-1109-CQ-546
Procedural posture
The United States District Court for the Southern District of Indiana certified three questions of Indiana law to the Indiana Supreme Court under Indiana Appellate Rule 64.
Precedential value
Published procedural order accepting certified questions; no merits holding on the underlying Indiana-law issues.
Parties
Loparex, LLC v. MPI Release Technologies, LLC, Gerald Kerber, Stephen Odders
Disposition
cert_granted

Topics

appellate procedurestatutory interpretationemployment lawremediescivil procedure

Practice areas

appellate procedureemployment lawstatutory interpretationremediescivil procedure

Questions Presented

  1. Whether the Indiana Supreme Court should accept the three certified questions of Indiana law under Indiana Appellate Rule 64.
  2. Whether Wabash Railroad Co. v. Young remains good law concerning voluntary departures from employment and claims under Indiana Code section 22-5-3-2.
  3. Whether attorney fees incurred in defending or prosecuting an unsuccessful claim under Indiana Code section 22-5-3-2 are recoverable as compensatory damages.
  4. Whether an unsuccessful suit seeking to protect alleged trade secrets and restrict a former employee's competitive employment provides a basis for recovery under Indiana Code section 22-5-3-2.

Holdings

  1. The Indiana Supreme Court accepted the three questions certified by the United States District Court for the Southern District of Indiana pursuant to Indiana Appellate Rule 64.

Key quotations

The certified questions, which each member of this Court has considered, are hereby ACCEPTED pursuant to Indiana Appellate Rule 64. (954 N.E.2d at 449)

Factual background

The federal action involved claims concerning Indiana Code section 22-5-3-2, attorney fees as compensatory damages, and an unsuccessful effort by a former employer to protect alleged trade secrets and restrict a former employee's competitive employment. The federal district court certified three Indiana-law questions to the Indiana Supreme Court for resolution.

Procedural history

The certified questions arose in a federal action, Loparex, LLC v. MPI Release Technologies, LLC, et al., pending in the Southern District of Indiana. The Indiana Supreme Court accepted the certified questions and established briefing, appendix, filing, service, appearance, and scheduling procedures; it did not decide the merits of the questions in this order.

Court Document

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