Indiana Code

Ind. Code § 32-31-8-6 (2026)

Tenant's cause of action to enforce landlord obligations

✓ current as of May 2026
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     Sec. 6. (a) A tenant may bring an action in a court with jurisdiction to enforce an obligation of a landlord under this chapter.

     (b) A tenant may not bring an action under this chapter unless the following conditions are met:

(1) The tenant gives the landlord notice of the landlord's noncompliance with a provision of this chapter.

(2) The landlord has been given a reasonable amount of time to make repairs or provide a remedy of the condition described in the tenant's notice. The tenant may not prevent the landlord from having access to the rental premises to make repairs or provide a remedy to the condition described in the tenant's notice.

(3) The landlord fails or refuses to repair or remedy the condition described in the tenant's notice.

     (c) This section may not be construed to limit a tenant's rights under IC 32-31-3, IC 32-31-5, or IC 32-31-6.

     (d) If the tenant is the prevailing party in an action under this section, the tenant may obtain any of the following, if appropriate under the circumstances:

(1) Recovery of the following:

(A) Actual damages and consequential damages.

(B) Attorney's fees and court costs.

(2) Injunctive relief.

(3) Any other remedy appropriate under the circumstances.

     (e) A landlord's liability for damages under subsection (d) begins when:

(1) the landlord has notice or actual knowledge of noncompliance; and

(2) the landlord has:

(A) refused to remedy the noncompliance; or

(B) failed to remedy the noncompliance within a reasonable amount of time following the notice or actual knowledge;

whichever occurs first.

As added by P.L.92-2002, SEC.2.

 

Notes of Decisions
Cited in 15 cases (3 in the last 5 years), 2003–2025 · leading case: John Doe 1 v. Indiana Dep't of Child Servs., 81 N.E.3d 199 (Ind. 2017).
John Doe 1 v. Indiana Dep't of Child Servs., 81 N.E.3d 199 (Ind. 2017). · cites it 4× “§ 32-31- 7-7 (2016) (tenant obligations); I.C. § 32-31-8-6 (2016) (landlord obligations); I.”
Erwin v. Roe, 928 N.E.2d 609 (Ind. Ct. App. 2010). · cites it 5× “However, before a tenant files suit against the landlord, he or she must comply with I.C. § 32-31-8-6(b). According to L.C. § 82-31-8-6(b), in order for a tenant to bring suit, the following prerequisites must be met: (1) The tenant gives the landlord notice of the landlord's…”
McCormick v. Kissel, 458 F. Supp. 2d 944 (S.D. Ind. 2006). · cites it 6× “In this instance, Plaintiffs’ Complaint contains no allegations that Plaintiffs gave Defendants the notice required in Ind. Code § 32-31-8-6 (b) or that Plaintiffs, after providing Defendants with notice, gave Defendants a reasonable amount of time to remedy the problems.”
Smith v. Hous. Auth., 867 F. Supp. 2d 1004 (N.D. Ind. 2012). · cites it 2× “Ind. Code § 32-31-8-6 . In their Amended Complaint the Smiths have alleged numerous problems related to the condition of the property including a broken and flooding toilet, a roach infestation, broken elevators and air conditioners, filthy carpet, open electrical light sockets,…”
Olympus Props., LLC v. Plotzker, 888 N.E.2d 334 (Ind. Ct. App. 2008). · cites it 2× “Attorney Fees The small claims court awarded Plotzker attorney fees of $7,505 pursuant to Ind.Code § 32-31-8-6. That section permits a court to award attorney fees if the tenant prevails in an action to enforce an obligation of a landlord.”
Rainbow Realty Grp., Inc., &/or Cress Trust v. Katrina Carter & Quentin Lintner, 112 N.E.3d 716 (Ind. Ct. App. 2018). · cites it 2× “Ind. Code § 32-31-8-6 (d). [31] The Lintners contend that the trial court abused its discretion in *726 awarding them only $3000 in attorney's fees after they submitted an affidavit of attorney's fees in the amount of $35,475.”
Syed Umar Husainy v. Granite Mgmt., LLC, & Jaffa Varsity 1, LLC (Ind. Ct. App. 2019). · cites it 8× “The jury also found in favor of Husainy on his Section 32-31-8-5 claim, which entitled him to seek attorney’s fees pursuant to Section 32-31-8-6, and awarded him $605 in damages.”
Xihui Wang v. Mingyu Sun (Ind. Ct. App. 2023). · cites it 8× “” Ind. Code § 32-31-8-6 (b)(2). [19] Here, Landlord and Tenant gave conflicting stories at trial.”
Monique J. Hartley (Mansfield) & Mark J. Mansfield v. Amity Reading (mem. dec.) (Ind. Ct. App. 2016). · cites it 5× “See Ind. Code § 32-31-8-6 (d) (West/Westlaw 2002).”
Fair Hous. Ctr. of Cent. Indiana, Inc. v. Rainbow Realty Grp., Inc. (S.D. Ind. 2021). · cites it 4× “The court’s order on the motion for class certification said that the plaintiffs’ claim seeking declaratory relief that Section 32-31-8-5 applies to Rainbow is a common question, but their claims for individual relief under Section 32-31-8-6 are not common. Rainbow argues that…”
Maple Tree LP, II v. Rachel Rebollo (Ind. Ct. App. 2025). · cites it 4× “Damages for failure to comply with section 32-31-8-5 are recoverable under Indiana Code section 32-31-8-6, which provides, in part, “[a] tenant may bring an action in a court with jurisdiction to enforce an obligation of a landlord under this chapter.”
Beverly Twilley v. Pangea Real Est., PP Indy 6, LLC & All Unknown Persons (mem. dec.) (Ind. Ct. App. 2017). · cites it 2× “This type of negotiation is precisely the sort of behavior sanctioned by our legislature, see Ind. Code § 32-31-8-6 (tenant cannot bring legal action against landlord unless “landlord fails or refuses to repair or remedy the condition”), and such mutual releases must be…”
— Ind. Code § 32-31-8-6(a) — 2 cases
Maple Tree LP, II v. Rachel Rebollo (Ind. Ct. App. 2025). “Damages for failure to comply with section 32-31-8-5 are recoverable under Indiana Code section 32-31-8-6, which provides, in part, “[a] tenant may bring an action in a court with jurisdiction to enforce an obligation of a landlord under this chapter.”
Vandenbosch v. Daily, 785 N.E.2d 666 (2003).
— Ind. Code § 32-31-8-6(b) — 2 cases
Erwin v. Roe, 928 N.E.2d 609 (Ind. Ct. App. 2010). “However, before a tenant files suit against the landlord, he or she must comply with I.C. § 32-31-8-6(b). According to L.C. § 82-31-8-6(b), in order for a tenant to bring suit, the following prerequisites must be met: (1) The tenant gives the landlord notice of the landlord's…”
McCormick v. Kissel, 458 F. Supp. 2d 944 (S.D. Ind. 2006). “In this instance, Plaintiffs’ Complaint contains no allegations that Plaintiffs gave Defendants the notice required in Ind. Code § 32-31-8-6 (b) or that Plaintiffs, after providing Defendants with notice, gave Defendants a reasonable amount of time to remedy the problems.”
— Ind. Code § 32-31-8-6(d) — 1 case
Xihui Wang v. Mingyu Sun (Ind. Ct. App. 2023). “” Ind. Code § 32-31-8-6 (b)(2). [19] Here, Landlord and Tenant gave conflicting stories at trial.”
— Ind. Code § 32-31-8-6(d)(1)(B) — 1 case
— Ind. Code § 32-31-8-6(d)(3) — 1 case
Syed Umar Husainy v. Granite Mgmt., LLC, & Jaffa Varsity 1, LLC (Ind. Ct. App. 2019). “The jury also found in favor of Husainy on his Section 32-31-8-5 claim, which entitled him to seek attorney’s fees pursuant to Section 32-31-8-6, and awarded him $605 in damages.”
— Ind. Code § 32-31-8-6(e) — 1 case
Erwin v. Roe, 928 N.E.2d 609 (Ind. Ct. App. 2010). “However, before a tenant files suit against the landlord, he or she must comply with I.C. § 32-31-8-6(b). According to L.C. § 82-31-8-6(b), in order for a tenant to bring suit, the following prerequisites must be met: (1) The tenant gives the landlord notice of the landlord's…”
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