Patrick Coughlin v. State of Indiana ex rel. Indiana Department of Workforce Development (mem. dec.)

CourtIndiana Court of Appeals
DecidedMay 23, 2019
Docket18A-PL-2846
StatusPublished

This text of Patrick Coughlin v. State of Indiana ex rel. Indiana Department of Workforce Development (mem. dec.) (Patrick Coughlin v. State of Indiana ex rel. Indiana Department of Workforce Development (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
Patrick Coughlin v. State of Indiana ex rel. Indiana Department of Workforce Development (mem. dec.), (Ind. Ct. App. 2019).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be FILED regarded as precedent or cited before any May 23 2019, 9:09 am

court except for the purpose of establishing CLERK Indiana Supreme Court the defense of res judicata, collateral Court of Appeals and Tax Court estoppel, or the law of the case.

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE David Paul Allen Curtis T. Hill, Jr. Hammond, Indiana Attorney General Sierra A. Murray Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Patrick Coughlin, May 23, 2019 Appellant-Respondent, Court of Appeals Case No. 18A-PL-2846 v. Appeal from the Lake Superior Court State of Indiana ex rel. The Honorable Bruce D. Parent, Indiana Department of Judge Workforce Development, Trial Court Cause No. Appellee-Petitioner 45D04-1801-PL-3

Crone, Judge.

Court of Appeals of Indiana | Memorandum Decision 18A-PL-2846 | May 23, 2019 Page 1 of 13 Case Summary [1] After the Indiana Department of Workforce Development (“DWD”)

determined that Patrick Coughlin received unemployment compensation

benefits to which he was not entitled, the State of Indiana filed a verified

petition for civil enforcement of the DWD’s determination. Coughlin moved

for summary judgment, asserting that the State’s claim was filed outside the

applicable statute of limitations. The State filed a cross-motion for summary

judgment on the merits of its claim. Coughlin then filed a motion to strike

portions of the evidence that the State designated in support of its cross-motion.

The trial court issued an order denying Coughlin’s motion for summary

judgment and his motion to strike and granted the State’s cross-motion for

summary judgment.

[2] Coughlin now appeals. He contends that he is entitled to summary judgment

because the State’s claim is barred by the statute of limitations. He also argues

that the trial court abused its discretion in denying his motion to strike because

the State’s designated evidence does not satisfy certain evidentiary rules

pertaining to affidavits and authenticity. Finding no error, we affirm.

Facts and Procedural History [3] Coughlin applied for and received unemployment compensation benefits in

fiscal years 2009 and 2010 through the DWD. Subsequently, the DWD

investigated his claims and concluded that he had failed to report income that

he had earned during the relevant time period. The DWD mailed Coughlin

Court of Appeals of Indiana | Memorandum Decision 18A-PL-2846 | May 23, 2019 Page 2 of 13 determinations of eligibility and notices of potential overpayment, informing

him that it had determined that he “knowingly failed to disclose or falsified

material facts,” which, if known, would have rendered him ineligible for

benefits. Appellant’s App. Vol. 2 at 27-33. The determinations of eligibility

informed Coughlin that he had received $8102.00 to which he was not entitled,

that penalties for the fraud would be assessed, and that interest on the balance

due would accrue monthly. Id. Further, the determinations of eligibility

informed Coughlin that they would become final unless appealed within ten

days. Id. Coughlin did not appeal. On January 30, 2012, the determinations of

eligibility became final.

[4] On January 8, 2018, the State filed a verified petition for civil enforcement of

the determinations of eligibility, alleging that Coughlin had failed to disclose

material facts which would have made him ineligible to receive unemployment

compensation benefits, resulting in an overpayment of $8102.00 and resulting

penalties of $4486.25. The petition was verified by the DWD’s keeper of

records, Whitney Cobb, and the notices of potential overpayment and the

determinations of eligibility were referenced in and attached to the petition as

exhibits. Id. at 20-33.

[5] In June 2018, Coughlin filed a motion for summary judgment, supporting

memorandum, and designated evidence, asserting that the State’s petition for

civil enforcement was filed outside the applicable period of limitations. In

August 2018, the State filed a cross-motion for summary judgment and

opposition to Coughlin’s motion for summary judgment with a supporting

Court of Appeals of Indiana | Memorandum Decision 18A-PL-2846 | May 23, 2019 Page 3 of 13 memorandum and designated evidence. The State argued that its petition was

timely and that “the undisputed facts of this case permit the court to determine

that after offsets, tax interceptions, and payments [Coughlin] is indebted to [the

State] in the amount of $11,592.03 plus continually accruing interest at one-half

percent per month.” Id. at 77. Coughlin then filed a motion to strike portions

of the State’s designated evidence.

[6] Following a hearing in October 2018, the trial court issued an order denying

Coughlin’s motion for summary judgment, denying his motion to strike, and

granting the State’s cross-motion for summary judgment. This appeal ensued.

Discussion and Decision

Section 1 – The trial court properly denied Coughlin’s motion for summary judgment. [7] Our review of summary judgments is well settled:

The purpose of summary judgment is to terminate litigation about which there can be no factual dispute and which can be determined as a matter of law. The party moving for summary judgment has the burden of making a prima facie showing that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. If the moving party meets its burden, the burden then shifts to the nonmoving party whose response must set forth specific facts indicating that there is an issue of material fact. Any doubts as to any facts or inferences to be drawn from those facts must be resolved in favor of the nonmoving party.

Court of Appeals of Indiana | Memorandum Decision 18A-PL-2846 | May 23, 2019 Page 4 of 13 We review a summary judgment ruling de novo. A trial court’s findings and conclusions offer insight into the rationale for the court’s judgment and facilitate appellate review but are not binding on this Court. Moreover, we are not constrained to the claims and arguments presented to the trial court, and we may affirm a summary judgment ruling on any theory supported by the designated evidence. Cross-motions for summary judgment do not alter this standard or change our analysis. The party that lost in the trial court has the burden of persuading us that the trial court erred.

Denson v. Estate of Dillard, 116 N.E.3d 535, 539 (Ind. Ct. App. 2018) (citations

and quotation marks omitted). “The defense of a statute of limitation is

peculiarly suitable as a basis for summary judgment.” LaCava v. LaCava, 907

N.E.2d 154, 162 (Ind. Ct. App. 2009) (quoting Morgan v. Benner, 712 N.E.2d

500, 502 (Ind. Ct. App. 1999), trans. denied).

[8] Coughlin argues that he is entitled to summary judgment as a matter of law

because the statute of limitations had run on the State’s claim. Specifically, he

asserts that the State filed its verified petition for civil enforcement almost six

years after the effective date of the determinations of eligibility, and therefore

failed to bring the civil enforcement action within the applicable statute of

limitations, which he contends is two years. “‘[T]he statute of limitation in

effect at the time a lawsuit is commenced governs the action regardless of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Indiana Spine Group v. Pilot Travel
959 N.E.2d 789 (Indiana Supreme Court, 2011)
Whitehouse v. Quinn
477 N.E.2d 270 (Indiana Supreme Court, 1985)
Skaggs v. Merchants Retail Credit Ass'n
519 N.E.2d 202 (Indiana Court of Appeals, 1988)
State v. Hensley
661 N.E.2d 1246 (Indiana Court of Appeals, 1996)
Morgan v. Benner
712 N.E.2d 500 (Indiana Court of Appeals, 1999)
Meisenhelder v. Zipp Express, Inc.
788 N.E.2d 924 (Indiana Court of Appeals, 2003)
Decker v. Zengler
883 N.E.2d 839 (Indiana Court of Appeals, 2008)
Haynes v. Contat
643 N.E.2d 941 (Indiana Court of Appeals, 1994)
LaCava v. LaCava
907 N.E.2d 154 (Indiana Court of Appeals, 2009)
Halterman v. Adams County Board of Commissioners
991 N.E.2d 987 (Indiana Court of Appeals, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Patrick Coughlin v. State of Indiana ex rel. Indiana Department of Workforce Development (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-coughlin-v-state-of-indiana-ex-rel-indiana-department-of-indctapp-2019.