Mobile Tire and Axle, Inc. v. Superior Tire, LLC (mem. dec.)

CourtIndiana Court of Appeals
DecidedJuly 14, 2015
Docket20A03-1411-PL-416
StatusPublished

This text of Mobile Tire and Axle, Inc. v. Superior Tire, LLC (mem. dec.) (Mobile Tire and Axle, Inc. v. Superior Tire, LLC (mem. dec.)) 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
Mobile Tire and Axle, Inc. v. Superior Tire, LLC (mem. dec.), (Ind. Ct. App. 2015).

Opinion

MEMORANDUM DECISION Jul 14 2015, 8:32 am Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral estoppel, or the law of the case.

ATTORNEYS FOR APPELLANT ATTORNEYS FOR APPELLEE Nancy A. McCaslin Brent E. Inabit James L. McCaslin Christopher M. Keefer McCaslin & McCaslin Sopko, Nussbaum, Inabit & Kaczmarek Elkhart, Indiana South Bend, Indiana

IN THE COURT OF APPEALS OF INDIANA

Mobile Tire and Axle, Inc., et al., July 14, 2015

Appellants-Defendants, Court of Appeals Case No. 20A03-1411-PL-416 v. Appeal from the Elkhart Superior Court

Superior Tire, LLC, et al., The Honorable Charles Carter Wicks, Judge Appellees-Plaintiffs Case No. 20D05-1111-PL-12

Vaidik, Chief Judge.

Case Summary In October 2014, a jury found that the owners of Mobile Tire and Axle, Inc.

(Mobile) had sabotaged the products of another company, Superior Tire, LLC

(Superior). The jury awarded Superior $287,366.35 in damages. On appeal,

Court of Appeals of Indiana | Memorandum Decision 20A03-1411-PL-416 | July 14, 2015 Page 1 of 14 Mobile contends that the trial court erred by refusing to lift an order in limine,

the jury’s verdict is not supported by the evidence, and the jury’s damage award

is not supported by the evidence. Because we find no merit to any of these

claims, we affirm.

Facts and Procedural History [1] Mobile and Superior are competitor companies—both sell new and used tires

and axles, primarily for mobile homes. Michael and Cheryl Fahlbeck created

Mobile in 1991. Mobile is a relatively small, family-run operation. By contrast,

Superior—created by Darrell Pritt in 1999—does business throughout the

country and has employed as many as seventy-five people at one time.

[2] In 2005, Superior began experiencing unexplained problems with its products.

Specifically, its customers began complaining that axle parts were missing,

brake lines had been cut, and tires were damaged—all issues that implicated

product safety. As a result of these problems, Superior had to perform

hundreds of un-reimbursable service repairs, and Darrell fired several

employees responsible for quality control. But Superior’s product problems

continued.

[3] In 2011, one of Mobile’s long-time customers took their business to Superior.

A few weeks later, the Fahlbecks approached one of their employees, Ryder

Tinkey, and asked him to sabotage Superior’s products. Tinkey had been

employed by Mobile for years and had been involved in dishonest business

Court of Appeals of Indiana | Memorandum Decision 20A03-1411-PL-416 | July 14, 2015 Page 2 of 14 practices there, including altering tire ratings and marketing used products as

new ones. Tinkey declined the Fahlbecks’ sabotage requests. A short time

later, he was fired. Tinkey then began contacting Mobile’s customers and

informing them about Mobile’s dishonest business practices.

[4] Tinkey later met with Darrell and told him that the Fahlbecks had been

sabotaging Superior’s products. Two months later, Superior filed a complaint

against Mobile in Elkhart Superior Court, alleging tortious interference with

business relationships and unfair competition, and seeking damages.

Notably—after experiencing issues with their products for more than six

years—Superior’s product problems vanished after filing its complaint.

[5] Before trial, Superior filed a motion in limine to prevent Mobile from

introducing evidence to support its claim that Tinkey was fired for using drugs.

The trial court granted the motion but ruled that the order in limine would be

lifted “in the event that [] Tinkey or others intentionally introduce evidence of

any allegation that [] Tinkey was wrongfully discharged from the employment

of Mobile[.]” Appellant’s App. p. 1042-43. A three-day jury trial began in

October 2014. During the trial, Superior put forth extensive evidence of the

product problems it experienced from 2005 to 2011. Darrell described how

“2005 was the year that got my attention” because his “repair rate probably

tripled, if not quadrupled . . . .” Tr. p. 464. He testified that key product parts,

such as dust caps, cotter pins, spindle nuts, and brake wires, simply went

missing. Id. at 465-66, 468. Superior also experienced problems with its tires—

tires were suddenly going flat “with slices in them and cuts in them.” Id. at 471.

Court of Appeals of Indiana | Memorandum Decision 20A03-1411-PL-416 | July 14, 2015 Page 3 of 14 This was happening “all over the place, everywhere,” and as a result, Superior

was replacing tires “all the time. And it got costly, very costly.” Id. Notably,

Darrell testified that these problems occurred after the products had passed

Superior’s inspection. Id. More than one Superior employee was fired during

this time, including Darrell’s best foreman, but the company’s problems

continued. Id. at 478, 480.

[6] Darrell told the jury that he “repaired everything. Not one time did I not

repair. Not one time. Replaced [the products] a lot.” Superior did not charge

its customers for these repairs—Darrell testified that the company performed

250 to 300 repairs—or for replacements. Id. at 477, 494. Darrell estimated that

these repairs cost approximately $90,000, but Mobile estimated the repair costs

to be $67,366.35. Id. at 666, 945. Both of these estimates were presented to the

jury. Darrell also testified that Superior lost goodwill with its customers. He

defined goodwill as:

being able to . . . walk in your customer’s door . . . unannounced, just walk in and check on your product and them be glad to see you. That’s goodwill to me. Goodwill to me is, if they have a problem when they call you up, they’re not chewing your butt out. They’re calling you up because they’ve got faith in you. They believe you’re going to fix the problem; they know you’re gonna be there for them. To me, that’s – that’s priceless. That’s the root of our business. That’s [what] we base our company’s [sic] on – when our customer [is] trusting us. That’s important. Id. at 555. He estimated that Superior lost $500 to $1000 per month in

customer goodwill from 2005 to 2014. Id. at 714. Mobile did not question

Darrell about this estimate.

Court of Appeals of Indiana | Memorandum Decision 20A03-1411-PL-416 | July 14, 2015 Page 4 of 14 [7] According to Darrell, everything changed after he received a call from Tinkey

in June 2011. As Darrell described it, Tinkey knew things about Superior’s

product problems that he “shouldn’t have known”:

He shouldn’t have known some of the problems I was having. He shouldn’t have known about my cotter pins. He shouldn’t have known about my U-bolt issues. He shouldn’t have known about brake wires. None of this stuff he should have known. He doesn’t work with me. I don’t know this guy from Adam. Never talked to him before in my life. Id. at 546. Tinkey told Darrell that his product problems had been caused by

“Mobile Tire and Axle. Mi[chael] and Cheryl.” Id. at 547.

[8] Tinkey testified for Superior. He described his involvement in dishonest

business practices at Mobile, including altering Mobile’s products to satisfy

customer orders when inventory ran low, id. at 614-17, and marketing used

products as new ones, id. at 619. Tinkey testified that he did these things

because the Fahlbecks told him to, and “I needed the job, and I knew, if I didn’t

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