Anita Haug v. Starke County

CourtIndiana Court of Appeals
DecidedMarch 11, 2026
Docket25A-PL-01826
StatusPublished

This text of Anita Haug v. Starke County (Anita Haug v. Starke County) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anita Haug v. Starke County, (Ind. Ct. App. 2026).

Opinion

IN THE

Court of Appeals of Indiana Anita Haug and Robert Haug, FILED Mar 11 2026, 9:16 am Appellants-Plaintiffs CLERK Indiana Supreme Court Court of Appeals and Tax Court v.

County of Starke, et al., Appellees-Defendants

March 11, 2026 Court of Appeals Case No. 25A-PL-1826 Appeal from the Starke Circuit Court The Honorable Micah P. Cox, Magistrate Trial Court Cause No. 75C01-2503-PL-5

Opinion by Chief Judge Tavitas Judges Bailey and Kenworthy concur.

Court of Appeals of Indiana | Opinion 25A-PL-1826 | March 11, 2026 Page 1 of 17 Tavitas, Chief Judge.

Case Summary [1] In 2023, Anita and Robert Haug filed a claim against Starke County (“the

County”) in federal court alleging that the County had taken their property

without just compensation. The Haugs later filed a motion to add a quiet title

claim to their federal complaint. The federal district court (“District Court”)

denied the Haugs’ motion to amend, concluding that it would be futile.

[2] In 2025, the Haugs filed the present quiet title action in Starke Circuit Court.

The County moved for summary judgment and claimed that the federal district

court’s denial of the motion for leave to amend was a judgment on the merits

under federal law and that the Haugs’ claim was, therefore, barred by res

judicata. The Haugs then filed a motion to strike the County’s filings on the

ground that the County lacked standing. The trial court granted the County’s

motion for summary judgment and denied the Haugs’ motion to strike. The

trial court also found the motion to strike to be frivolous and awarded the

County attorney fees in the amount of $1,135.20.

[3] The Haugs appeal and argue: (1) the trial court erred in granting the County’s

motion for summary judgment because the federal District Court’s order

denying their motion for leave to amend was not a judgment on the merits; and

(2) the trial court erred by denying the Haugs’ motion to strike and awarding

attorney fees to the County. We disagree and, accordingly, affirm. The County

requests the award of appellate attorney fees, which we decline.

Court of Appeals of Indiana | Opinion 25A-PL-1826 | March 11, 2026 Page 2 of 17 Issues [4] The Haugs present four issues, which we consolidate and restate as:

I. Whether the trial court erred by granting the County’s motion for summary judgment.

II. Whether the trial court erred by denying the Haugs’ motion to strike and awarding attorney fees to the County.

The County presents one additional issue: whether we should award the

County appellate attorney fees.

Facts A. Background

[5] The Haugs own property near Koontz Lake in Starke County. The Haugs

claim that their property line extends to the shore of Koontz Lake. The plat

map referenced in the deed conveyed to the Haugs when they purchased the

property, however, depicts the Haugs’ plots with boundary lines that end just

shy of the lakefront. The County claims that the area between the Haugs’

property lines and the lakefront is a public beach. The Haugs argue that their

property extends to the lakefront and that the public beach was never used as

such until recently.

B. Federal District Court Action

[6] On May 16, 2023, the Haugs filed an action in the United States District Court

for the Northern District of Indiana, in which they alleged that the County had

Court of Appeals of Indiana | Opinion 25A-PL-1826 | March 11, 2026 Page 3 of 17 converted their private lakefront property into a public beach without just

compensation, thereby constituting an unconstitutional taking under the Fifth

Amendment. After the deadline for the amendment of pleadings had passed,

the Haugs filed a motion in the District Court seeking leave to file an amended

complaint that would add two counts against the County: (a) a quiet title

action; and (b) an equal protection claim for their property being singled out for

use as a public beach.

[7] On December 19, 2024, the District Court issued an order denying the Haugs’

motion for leave to amend the complaint to add the two counts. The District

Court deemed that the proposed amendments would be futile. Under federal

procedure, if the claims proposed to be added to the complaint are “so legally

infirm as to be futile, there is no reason to grant leave to bring them into the

lawsuit.” Thomas v. Dart, 39 F.4th 835, 841 (7th Cir. 2022). “This is

‘essentially’ the same as saying a party has failed to state a claim.” Appellant’s

App. Vol. II p. 67 (quoting Thomas, 39 F.4th at 841). The District Court

determined that the quiet title claim did not meet the requirements of Indiana’s

quiet title statute 1 and instead appeared to be a claim of adverse possession,

which cannot be brought against a governmental unit in Indiana. See Ind. Dep’t

of Nat. Res. v. Ritz, 945 N.E.2d 209, 215 (Ind. Ct. App. 2011), trans. denied. 2

1 Ind. Code § 32-30-3-14. 2 The Haugs’ takings claim remains pending before the District Court as of the date of this opinion.

Court of Appeals of Indiana | Opinion 25A-PL-1826 | March 11, 2026 Page 4 of 17 C. State Court Action

[8] On March 7, 2025, the Haugs brought a quiet title action in Starke Circuit

Court against Christian J. Koch, Ignatius A. Schimek, “Unknown Parties,” and

“All Persons Unknown, Claiming Any Legal or Equitable Right, Title, Estate,

Lien, or Interest in the Property.” Appellant’s App. Vol. II p. 26 (capitalization

altered). The Haugs alleged that they have possession of the disputed area by

both title and, alternatively, through adverse possession.

[9] The County filed an appearance in this cause and, on April 7, 2025, filed a

motion for summary judgment. The County argued that the District Court’s

order denying the Haugs permission to amend their complaint to add the quiet

title action was a judgment on the merits and that the Haugs’ current quiet title

action was barred by res judicata. The Haugs responded to the County’s

motion on April 30, 2025, by filing a motion to strike a land appraisal report

designated by the County. And on May 6, 2025, the Haugs filed a response to

the County’s motion for summary judgment along with a designation of

evidence. The Haugs argued that the District Court’s denial of the motion for

leave to amend was not a judgment on the merits and did not have preclusive

effect.

[10] On June 9, 2025, the Haugs filed a second motion to strike in which they asked

the trial court to strike all of the County’s filings on the ground that the County

lacked standing. The Haugs argued that the County presented no evidence of

any legal interest in the disputed property because the County had no recorded

title to the property. Court of Appeals of Indiana | Opinion 25A-PL-1826 | March 11, 2026 Page 5 of 17 [11] The trial court held a hearing on the pending motions on June 2, 2025, and

issued two orders on July 7, 2025. The first order granted the County’s motion

for summary judgment. The second order denied the Haugs’ second motion to

strike as “unreasonable and groundless,” and ordered the Haugs to pay the

County attorney fees pursuant to Indiana Code Section 34-52-1-1(b). On July

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Anita Haug v. Starke County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anita-haug-v-starke-county-indctapp-2026.