occurrence rule (Indiana) · Go Syfert
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occurrence rule in Indiana

16 Indiana opinions name it 2 courts 1979–2017 0 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Havens v. Ritcheygreen
ind · 1991 · cited in 3 Indiana opinions naming this issue, 1992–1997
2 sentences

1997In Havens v. Ritchey, 582 N.E.2d 792, 795 (Ind.1991), our supreme court noted that "Indiana courts have previously acknowledged the inherent harshness of the occurrence rule on certain plaintiffs, but have found the rule to be reasonable in light of other policies intended to be furthered by the rule." If two years is no longer a reasonable time for the bringing of a medical malpractice action, see Bunker, supra, the legislature, not the court of appeals, needs to re-visit the rule.

1997In Havens v. Ritchey, 582 N.E.2d 792, 795 (Ind.1991), our supreme court noted that “Indiana courts have previously acknowledged the inherent harshness of the occurrence rule on certain plaintiffs, but have found the rule to be reasonable in light of other policies intended to be furthered by the rule.” If two years is no longer a reasonable time for the bringing of a medical malpractice action, see Bunker, supra, the legislature, not the court of appeals, needs to revisit the rule.

23
Rohrabaugh Ex Rel. Cross v. Wagonergreen
ind · 1980 · cited in 3 Indiana opinions naming this issue, 1989–1995
2 sentences

1995See, e.g., Havens v. Ritchey (1991), Ind., 582 N.E.2d 792, 795 ("inherent harshness of the occurrence rule on certain plaintiffs"); Rohrabaugh v. Wagoner (1980), Ind., 413 N.E.2d 891, 895 ("no doubt that this measure is a stern one and will have harsh application in individual cases").

1991See Rohrabaugh, 274 Ind. 661 , 413 N.E.2d 891 ; Jones v. Cloyd (1989), Ind.App., 534 N.E.2d 257 .

23
Alwood v. Davisgreen
indctapp · 1980 · cited in 5 Indiana opinions naming this issue, 1982–1997
2 sentences

1997Indeed, over a decade ago, a panel of this court considered the large number of plaintiffs left without a remedy under the occur rence-based statute of limitations and said, “[w]e have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.” Atwood v. Davis, 411 N.E.2d 759, 761 (Ind.Ct.

1997But see Alwood v. Davis (1980) Ind.App., 411 N.E.2d 759, 761 (“We have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.”) It may well be that our Supreme Court should and will revisit the issues presented both by this ease and by Martin v. Richey, supra. Until such time, however, the latitude afforded such policy determinations by the legislature or by administrative rules or regulations must receive our deference.

15
Cinergy Corp. v. Associated Electric & Gas Insurance Services, Ltd.green
ind · 2007 · cited in 3 Indiana opinions naming this issue, 2009–2012
2 sentences

2012The court discerned “no ambiguity here that would permit the occurrence requirement reasonably to be understood to allow coverage for damages in the form of installation costs for government-mandated equipment intended to reduce future emissions of pollutants and to prevent future environmental harm.” Id.

2012The court discerned “no ambiguity here that would permit the occurrence requirement reasonably to be understood to allow coverage for damages in the form of installation costs for government-mandated equipment intended to reduce future emissions of pollutants and to prevent future environmental harm.” Id.

13
Woodson v. Stategreen
indctapp · 2012 · cited in 1 Indiana opinions naming this issue, 2017–2017
1 sentence

2017“The State need not present separate proof of impairment of action, impairment of thought, and loss of control of faculties to establish an individual’s intoxication.” Woodson v. State, 966 N.E.2d 135, 142 (Ind. Ct. App. 2012), trans. denied.

11

Distinguished, questioned or overruled (2)

CaseNegativeCited
Alwood v. Davisgreen
indctapp · 1980 · cited in 5 Indiana opinions naming this issue, 1982–1997
2 sentences

1997Indeed, over a decade ago, a panel of this court considered the large number of plaintiffs left without a remedy under the occur rence-based statute of limitations and said, “[w]e have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.” Atwood v. Davis, 411 N.E.2d 759, 761 (Ind.Ct.

1997But see Alwood v. Davis (1980) Ind.App., 411 N.E.2d 759, 761 (“We have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.”) It may well be that our Supreme Court should and will revisit the issues presented both by this ease and by Martin v. Richey, supra. Until such time, however, the latitude afforded such policy determinations by the legislature or by administrative rules or regulations must receive our deference.

15
Martin v. Richeygreen
indctapp · 1997 · cited in 1 Indiana opinions naming this issue, 1997–1997
2 sentences

1997But see Alwood v. Davis (1980) Ind.App., 411 N.E.2d 759, 761 ("We have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.") It may well be that our Supreme Court should and will revisit the issues presented both by this case and by Martin v. Richey, supra .

1997But see Alwood v. Davis (1980) Ind.App., 411 N.E.2d 759, 761 (“We have not though, ruled out the possibility of deciding in a future case that this occurrence rule must be applied as though it was a discovery rule due to the questionable constitutionality of the occurrence rule.”) It may well be that our Supreme Court should and will revisit the issues presented both by this ease and by Martin v. Richey, supra. Until such time, however, the latitude afforded such policy determinations by the legislature or by administrative rules or regulations must receive our deference.

11

Also cited on this issue (16)

CaseCitedYears
Davis v. State green
ind · 2004
1 sentence

2017Id. [13] The offense of operating a vehicle while intoxicated is governed by Ind. Code § 9-30-5-2 , which provides that “a person who operates a vehicle while intoxicated commits a Class C misdemeanor.” Ind. Code § 9-30-5-3 (a)(1) provides that a person who violates section 1 or 2 of this chapter commits a Level 6 felony if . . . the person has a previous conviction of operating while intoxicated that occurred within the five (5) years immediately preceding the occurrence of the violation of section 1 or 2 of this chapter[.] “Intoxicated” means under the influence of alcohol, a controlled subs

12017–2017
Fought v. State green
indctapp · 2008
1 sentence

2015Id. [11] The offense of operating a vehicle while intoxicated is governed by Ind. Code § 9-30-5-2 , which provides that “a person who operates a vehicle while intoxicated commits a Class C misdemeanor.” At the time of the offense, Ind. Code § 9-30-5-32 provided that a person who violates Ind. Code § 9-30-5-2 commits a class D felony if the person has a prior conviction of operating while intoxicated that occurred within five years immediately preceding the occurrence of the violation of Ind. Code § 9-30-5-2 .

12015–2015
Bunker v. National Gypsum Co. green
ind · 1982
2 sentences

1997In Havens v. Ritchey, 582 N.E.2d 792, 795 (Ind.1991), our supreme court noted that "Indiana courts have previously acknowledged the inherent harshness of the occurrence rule on certain plaintiffs, but have found the rule to be reasonable in light of other policies intended to be furthered by the rule." If two years is no longer a reasonable time for the bringing of a medical malpractice action, see Bunker, supra, the legislature, not the court of appeals, needs to re-visit the rule.

1997In Havens v. Ritchey, 582 N.E.2d 792, 795 (Ind.1991), our supreme court noted that “Indiana courts have previously acknowledged the inherent harshness of the occurrence rule on certain plaintiffs, but have found the rule to be reasonable in light of other policies intended to be furthered by the rule.” If two years is no longer a reasonable time for the bringing of a medical malpractice action, see Bunker, supra, the legislature, not the court of appeals, needs to revisit the rule.

11997–1997
Wehling v. Citizens National Bank green
ind · 1992
1 sentence

1992Bank (1992), Ind., 586 N.E.2d 840 , in which our supreme court held that a merged discovery and ascertainment rule applies in all tort claims, the occurrence rule continues to apply in medical malpractice claims.

11992–1992
Jones v. Cloyd green
indctapp · 1989
1 sentence

1991See Rohrabaugh, 274 Ind. 661 , 413 N.E.2d 891 ; Jones v. Cloyd (1989), Ind.App., 534 N.E.2d 257 .

11991–1991
Martin v. Rinck green
indctapp · 1986
1 sentence

1989Martin v. Rinck (1986), Ind. App., 501 N.E.2d 1086 ; Colbert v. Waitt, supra ; Frady v. Hedgcock (1986), Ind. App., 497 N.E.2d 620, 622 , trans. denied. *260 Moreover, our courts have acknowledged the inherent harshness of such an occurrence rule on certain plaintiffs but have found the rule to be reasonable in light of other policies intended to be furthered by it.

11989–1989
Corbert v. Waitt green
indctapp · 1982
1 sentence

1989Martin v. Rinck (1986), Ind. App., 501 N.E.2d 1086 ; Colbert v. Waitt, supra ; Frady v. Hedgcock (1986), Ind. App., 497 N.E.2d 620, 622 , trans. denied. *260 Moreover, our courts have acknowledged the inherent harshness of such an occurrence rule on certain plaintiffs but have found the rule to be reasonable in light of other policies intended to be furthered by it.

11989–1989
Frady v. Hedgcock green
indctapp · 1986
1 sentence

1989Martin v. Rinck (1986), Ind. App., 501 N.E.2d 1086 ; Colbert v. Waitt, supra ; Frady v. Hedgcock (1986), Ind. App., 497 N.E.2d 620, 622 , trans. denied. *260 Moreover, our courts have acknowledged the inherent harshness of such an occurrence rule on certain plaintiffs but have found the rule to be reasonable in light of other policies intended to be furthered by it.

11989–1989
Guy v. SCHULDT green
ind · 1956
2 sentences

1985Guy v. Schuldt (1956), 236 Ind. 101 , 188 N.E.2d 891 ; Conard v. Waugh (1985), Ind.App., 474 N.E.2d 180 ; Spoljaric v. Pangan (1984), Ind.App., 466 N.E.2d 37 .

1985Guy v. Schuldt (1956), 236 Ind. 101 , 138 N.E.2d 891 ; Conard v. Waugh (1985), Ind. App., 474 N.E.2d 130 ; Spoljaric v. Pangan (1984), Ind. App., 466 N.E.2d 37 .

11985–1985
Spoljaric v. Pangan green
indctapp · 1984
2 sentences

1985Guy v. Schuldt (1956), 236 Ind. 101 , 188 N.E.2d 891 ; Conard v. Waugh (1985), Ind.App., 474 N.E.2d 180 ; Spoljaric v. Pangan (1984), Ind.App., 466 N.E.2d 37 .

1985Guy v. Schuldt (1956), 236 Ind. 101 , 138 N.E.2d 891 ; Conard v. Waugh (1985), Ind. App., 474 N.E.2d 130 ; Spoljaric v. Pangan (1984), Ind. App., 466 N.E.2d 37 .

11985–1985
Conard v. Waugh green
indctapp · 1985
1 sentence

1985Guy v. Schuldt (1956), 236 Ind. 101 , 138 N.E.2d 891 ; Conard v. Waugh (1985), Ind. App., 474 N.E.2d 130 ; Spoljaric v. Pangan (1984), Ind. App., 466 N.E.2d 37 .

11985–1985
Ayers v. Morgan green
pa · 1959
2 sentences

1983Our supreme court in Chaffin v. Nicosia, (1974) 261 Ind. 698, 702 , 310 N.E.2d 867, 870 , in holding that the statute granting minors until two years after attaining majority to institute actions controlled over the two years from the act, neglect, or omission provision of IC 34-4-19-1 (the 1941 act) 4 observed, quoting from Ayers v. Morgan, (1959) 397 Pa. 282 , 154 A.2d 788 , “it would be illogical and unintelligent to say that a person who does not know, and cannot know ... would be denied damages because his claim was filed, due to delay in learning . .. more than two years after the operat

1983Our supreme court in Chaffin v. Nicosia, (1974) 261 Ind. 698, 702 , 310 N.E.2d 867, 870 , in holding that the statute granting minors until two years after attaining majority to institute actions controlled over the two years from the act, neglect, or omission provision of IC 34-4-19-1 (the 1941 act) 4 observed, quoting from Ayers v. Morgan, (1959) 397 Pa. 282 , 154 A.2d 788 , “it would be illogical and unintelligent to say that a person who does not know, and cannot know ... would be denied damages because his claim was filed, due to delay in learning . .. more than two years after the operat

11983–1983
Adams v. Luros green
indctapp · 1980
1 sentence

1983In Adams v. Luros, (1980) Ind.App., 406 N.E.2d 1199 , the plaintiff saw the physician in January 1973 for back pain and partial paralysis of the leg.

11983–1983
Chaffin v. Nicosia green
ind · 1974
2 sentences

1983Our supreme court in Chaffin v. Nicosia, (1974) 261 Ind. 698, 702 , 310 N.E.2d 867, 870 , in holding that the statute granting minors until two years after attaining majority to institute actions controlled over the two years from the act, neglect, or omission provision of IC 34-4-19-1 (the 1941 act) 4 observed, quoting from Ayers v. Morgan, (1959) 397 Pa. 282 , 154 A.2d 788 , “it would be illogical and unintelligent to say that a person who does not know, and cannot know ... would be denied damages because his claim was filed, due to delay in learning . .. more than two years after the operat

1983Our supreme court in Chaffin v. Nicosia, (1974) 261 Ind. 698, 702 , 310 N.E.2d 867, 870 , in holding that the statute granting minors until two years after attaining majority to institute actions controlled over the two years from the act, neglect, or omission provision of IC 34-4-19-1 (the 1941 act) 4 observed, quoting from Ayers v. Morgan, (1959) 397 Pa. 282 , 154 A.2d 788 , “it would be illogical and unintelligent to say that a person who does not know, and cannot know ... would be denied damages because his claim was filed, due to delay in learning . .. more than two years after the operat

11983–1983
City of Fort Wayne v. Cameron green
ind · 1977
2 sentences

1980Later, in City of Fort Wayne v. Cameron, (1977) 267 Ind. 329 , 370 N.E.2d 338 , the Supreme Court refused to strictly apply an occurrence rule in a situation analogous to this case.

1980Later, in City of Fort Wayne v. Cameron, (1977) 267 Ind. 329 , 370 N.E.2d 338 , the Supreme Court refused to strictly apply an occurrence rule in a situation analogous to this case.

11980–1980
State v. Thompson green
indctapp · 1979
1 sentence

1979We think that our recent decision in State v. Thompson, (1979) Ind.App., 385 N.E.2d 198 , is likewise distinguishable where this court held that the provisions of Ind.Code 34-4-16.5-4, which would have limited recovery to $300,000 in Thompson , were inapplicable to a judgment on a jury verdict rendered after the effective date of the Act.

11979–1979

Where else courts name it

CT 43 (1988–2025) MS 36 (1974–2023) OH 21 (1989–2025) PA 20 (1978–2025) GA 18 (1940–2026) TX 17 (1948–2020) CA 16 (1946–2022) IN 16 (1979–2017) NY 16 (1945–2024) IL 14 (1948–2023) NJ 14 (1957–2025) NM 13 (1996–2022) NE 12 (1984–2022) SD 12 (1990–2020) KS 10 (1988–2015) WA 9 (1995–2026) AR 8 (1973–2020) MO 8 (1980–2025) LA 7 (1983–2019) KY 6 (1997–2025) AL 6 (1946–2015) ME 6 (1996–2019) MN 5 (1945–2017) FL 5 (1958–2014) DC 4 (1997–2014) NV 4 (1963–2014) MD 4 (1974–2022) NC 4 (1948–1996) TN 3 (2014–2019) AZ 3 (1981–2010) DE 3 (1977–2025) AK 3 (1990–2016) OR 3 (1945–2008) OK 3 (1950–2023) WV 2 (1979–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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