relation-back doctrine (Indiana) · Go Syfert
← Indiana issues

relation-back doctrine in Indiana

12 Indiana opinions name it 1 courts 1990–2026 1 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 (2)

CaseFollowedCited
Raisor v. Jimmie's Raceway Pub, Inc.green
indctapp · 2011 · cited in 2 Indiana opinions naming this issue, 2017–2018
2 sentences

2018"The party who seeks the benefit of the relation back doctrine bears the burden of proving that the conditions of Trial Rule 15(C) are met." Raisor , 946 N.E.2d at 76 . [21] Initially, Webb contends that the trial court erred in granting summary judgment as to the Corporation and the Park Board because the Amended Complaint related back based on the language of the order granting her leave to amend her complaint, and the Corporation's and the Park Board's arguments for summary judgment were untimely.

2017Raisor v. Jimmie’s Raceway Pub, Inc., 946 N.E.2d 72, 76 (Ind. Ct. App. 2011) (citing Ind. Trial Rule 15(C)). 2 “The party who seeks the benefit of the relation back doctrine bears the burden of proving that the conditions of Trial Rule 15(C) are met.” Id.

12
Corcoran v. Stategreen
ind · 2006 · cited in 1 Indiana opinions naming this issue, 2013–2013
1 sentence

2013Moreover, “[a]fter a filing deadline has elapsed, a party is not permitted to amend a petition to cure its procedural defects.” *132 Corcoran v. State, 845 N.E.2d 1019, 1022 (Ind.2006).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Mordacq v. State green
indctapp · 1992
2 sentences

2026The court reached this interpretation because it reasoned that, “in a case where the officer did not observe the defendant operating the vehicle”—such as cases where the defendant “stop[s] of their own accord, or by accident”— “the statutes could be read to impose no limit on the relation back of the test, provided the test was performed within three hours of the time an officer investigated the defendant,” and such an interpretation “could lead to absurd and illogical results unintended by the legislature.” 8 Id. at 27 .

2018Mannix v. State , 54 N.E.3d 1002 (Ind. Ct. App. 2016). [34] Among the cases that Corbin cites to is Mordacq v. State , 585 N.E.2d 22 , 23 (Ind. Ct. App. 1992), where this court discussed whether the chemical breath test can "presumptively relate back to an act of operating a vehicle that occurred before an officer encountered the defendant ...." Analyzing this issue, we determined that [I]n a case where the officer did not observe the defendant operating the vehicle, the statutes could be read to impose no limit on the relation back test, provided the test was performed within three hours of t

31992–2026
Charles Brown v. Vanderburgh County Sheriff's Department and Vanderburgh County, Indiana green
indctapp · 2017
1 sentence

2019“The party who seeks the benefit of the relation back doctrine bears the burden of proving that the conditions of Trial Rule 15(C) are met.” Id. at 870 .

12019–2019
RIETH-RILEY CONST. CO., INC. v. Gibson green
indctapp · 2010
1 sentence

2019Court of Appeals of Indiana | Memorandum Decision 19A-CC-319 | October 31, 2019 Page 10 of 12 Rieth-Riley, 923 N.E.2d at 477–78 (citations omitted).

12019–2019
Morgan Mannix v. State of Indiana green
indctapp · 2016
1 sentence

2018Mannix v. State , 54 N.E.3d 1002 (Ind. Ct. App. 2016). [34] Among the cases that Corbin cites to is Mordacq v. State , 585 N.E.2d 22 , 23 (Ind. Ct. App. 1992), where this court discussed whether the chemical breath test can "presumptively relate back to an act of operating a vehicle that occurred before an officer encountered the defendant ...." Analyzing this issue, we determined that [I]n a case where the officer did not observe the defendant operating the vehicle, the statutes could be read to impose no limit on the relation back test, provided the test was performed within three hours of t

12018–2018
Michael Howard v. Allen County Board of Zoning, Appeals and Alvin Schmucker green
indctapp · 2013
1 sentence

2014Myers Cooper cites Howard v. Allen County Board of Zoning Appeals, 991 N.E.2d at 131 , for the proposition that Trial Rule 15 and the relation-back doctrine do not allow a petitioner to amend its petition after it has been filed.

12014–2014
Crossroads Service Center, Inc. v. Coley green
indctapp · 2006
1 sentence

2011Coley, 842 N.E.2d at 825 .

12011–2011
National City Bank of Evansville v. Oldham green
indctapp · 1989
1 sentence

1996I.C. § 32-3-2-3; National City, 537 N.E.2d 1193 .

11996–1996
Gibson v. Miami Valley Milk Producers, Inc. green
indctapp · 1973
2 sentences

1990Similarly, Gibson v. Miami Valley Milk Producers, Inc. (1973), 157 Ind.App. 218 , 299 N.E.2d 631 , relied upon by the Hospital, concerns relation back in the context of addition of a new party, not relation back of a claim. .

1990Similarly, Gibson v. Miami Valley Milk Producers, Inc. (1973), 157 Ind.App. 218 , 299 N.E.2d 631 , relied upon by the Hospital, concerns relation back in the context of addition of a new party, not relation back of a claim. .

11990–1990

Where else courts name it

NY 429 (1929–2026) CA 143 (1965–2025) IL 123 (1962–2026) TX 95 (1958–2025) AL 73 (1984–2026) MI 67 (1977–2026) FL 59 (1961–2025) CT 56 (1988–2023) NC 40 (1971–2025) IA 36 (1992–2026) MD 27 (1962–2022) ID 26 (1984–2018) MS 22 (1987–2018) NJ 22 (1975–2025) CO 18 (1966–2016) LA 18 (1985–2023) PA 17 (1971–2025) OK 16 (1964–2017) UT 16 (1925–2025) GA 16 (1933–2026) MA 15 (1961–2020) MO 15 (1977–2023) OH 14 (1962–2024) WA 13 (1978–2021) IN 12 (1990–2026) TN 12 (1994–2026) MN 9 (1985–2012) DE 9 (1997–2025) NE 8 (1994–2023) MT 8 (1929–2026) AK 8 (1985–2021) OR 7 (1964–2016) NM 7 (1981–2013) AZ 6 (1981–2016) SD 6 (1994–2018) KY 6 (2005–2026) AR 6 (2003–2025) NV 6 (1993–2016) WY 6 (2004–2021) VA 5 (2003–2026) KS 5 (1977–2018) DC 4 (1977–2019) WV 4 (1990–2020) VT 3 (2006–2026) WI 3 (2010–2016) VI 3 (2012–2015) RI 3 (1995–2010) ND 2 (2004–2004) HI 2 (2005–2006)

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.

← Caselaw search · G Cite Topics · Brief Check