BlogLine

Indiana Supreme Court doubles down on finality: Post judgment amendments barred

12/22/25

By: Donald Patrick Eckler

Earlier this year, we wrote about the Indiana Supreme Court’s decision in Automotive Finance Corp. v. Liu, 250 N.E.3d 406 (2025), which emphasized that the finality of judgments outweighs competing arguments grounded in fairness. That case made clear that once judgment is entered, later challenges are tightly constrained and must fit within the structure of the rules. The court’s new decision in Brooks v. USA Track & Field, 2025 WL 3652673 reinforces and expands that guidance. Where Liu involved a post judgment attack under Trial Rule 60(B)(3), Brooks confirms that after final judgment there is simply no live pleading to amend, and Trial Rule 15(A) cannot be used to add claims. Both opinions reflect a strong commitment to procedural certainty and litigation closure.

In Brooks, a world class heptathlete collapsed during the 2021 Olympic Trials amid extreme heat, ending her bid to make the U.S. Olympic team. She sued USA Track & Field in Marion Superior Court, seeking a declaration that the release and indemnification agreement she signed before the event was unenforceable. Her stated goal was to clear the contractual obstacles before pursuing tort claims arising from the incident.

The case moved quickly. Both sides filed motions for summary judgment. Brooks asked for a ruling before the statute of limitations expired so she could determine whether to add tort claims. Two days before the deadline, the trial court granted USA Track & Field’s motion for summary judgment, denied Brooks’ motion and entered final judgment.

Faced with the closing limitations period and an adverse ruling, Brooks moved to amend her complaint to add tort claims and additional parties and moved to stay proceedings on those new claims. The trial court denied both, explaining that the case was over. The Indiana Court of Appeals agreed that summary judgment was proper but held that the trial court should have allowed amendment under Trial Rule 15(A).

On transfer, the Indiana Supreme Court brought the case back in line with its reasoning in Liu. The court explained that once summary judgment resolved all claims as to all parties, there was no operative pleading to amend. Trial Rule 15(A) does not apply after final judgment, and a trial court lacks discretion to permit amendment unless the judgment is first set aside under Trial Rule 59 or 60. Concerns about timing did not change the outcome. According to the court, Brooks could have moved to amend before judgment or filed a new complaint in the remaining days before limitations expired.

In a solo dissent, Justice Goff viewed the release as unenforceable and would have let the tort claims proceed. But the majority did not wade into that substantive dispute, instead centering its analysis on process and the structural value of finality.

For practitioners, Brooks offers practical direction: anticipate summary judgment as a true end point and plan amendments well before the court rules. If judgment forecloses claims, relief must be sought through the post judgment mechanisms in Trial Rules 59 or 60, or through a separate filing if time permits. Brooks and Liu together show that, in Indiana, procedural back doors are closed and predictably ending litigation.

For more information, please contact Donald Patrick Eckler at patrick.eckler@fmglaw.com or your local FMG attorney.

Information conveyed herein should not be construed as legal advice or represent any specific or binding policy or procedure of any organization. Information provided is for educational purposes only. These materials are written in a general format and not intended to be advice applicable to any specific circumstance. Legal opinions may vary when based on subtle factual distinctions. All rights reserved. No part of this presentation may be reproduced, published or posted without the written permission of Freeman Mathis & Gary, LLP.