Timothy Stabosz v. Shaw Friedman

CourtIndiana Court of Appeals
DecidedDecember 22, 2025
Docket24A-PL-02536
StatusPublished

This text of Timothy Stabosz v. Shaw Friedman (Timothy Stabosz v. Shaw Friedman) 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
Timothy Stabosz v. Shaw Friedman, (Ind. Ct. App. 2025).

Opinion

FILED Dec 22 2025, 8:57 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Timothy Stabosz, Appellant-Defendant/Cross-Appellee

v.

Shaw Friedman, Appellee-Plaintiff/Cross-Appellant

December 22, 2025 Court of Appeals Case No. 24A-PL-2536 Appeal from the LaPorte Circuit Court The Honorable Stephen R. Bowers, Special Judge Trial Court Cause No. 46C01-2106-PL-1110

Opinion by Judge Brown Judges Weissmann and Felix concur.

Court of Appeals of Indiana | Opinion 24A-PL-2536 | December 22, 2025 Page 1 of 16 Brown, Judge.

[1] Timothy Stabosz appeals the trial court’s order reinstating an order belatedly

granting a Motion to Correct Error filed by Shaw Friedman after the motion

was deemed denied pursuant to Ind. Trial Rule 53.3. On cross-appeal,

Friedman seeks appellate review of the issues raised in his Motion to Correct

Error. We reverse and vacate the belated order and reinstate the jury verdict in

favor of Stabosz.

Facts and Procedural History

[2] During the relevant time period, Stabosz served as the elected Auditor of

LaPorte County and Friedman served as the LaPorte County Attorney. On

February 10, 2021, Friedman filed a Complaint for Defamation against Stabosz

alleging that Stabosz had defamed him through various statements made in

emails and social media posts. On May 18, 2021, Stabosz filed a Motion to

Dismiss pursuant to the Indiana Anti-SLAPP Act, Ind. Code § 34-7-7-9, which

was denied by the trial court on December 7, 2021. Friedman filed a Second

Amended Complaint on December 13, 2021. Stabosz filed an interlocutory

appeal of the trial court’s denial of his Motion to Dismiss, and this Court

affirmed the denial in a published opinion. See Stabosz v. Friedman, 199 N.E.3d

Court of Appeals of Indiana | Opinion 24A-PL-2536 | December 22, 2025 Page 2 of 16 800 (Ind. Ct. App. 2022), trans. denied. On April 6, 2023, the Indiana Supreme

Court denied transfer by a vote of 3-2.1

[3] A five-day jury trial began on June 24, 2024. On June 28, 2024, the jury

returned a unanimous verdict in favor of Stabosz. On July 27, 2024, Friedman

filed a Motion to Correct Error raising five grounds for relief and requesting a

new trial. Specifically, Friedman asserted: (1) the verdict is against the weight

of the evidence or, clearly erroneous as contrary or not supported by the

evidence; (2) the court committed reversible error in modifying Final

Instruction No. 8; (3) the court abused its discretion in excluding the testimony

of former Indiana Supreme Court Justice Steven H. David; (4) the affidavit of

an alternate juror establishes that at least one juror disregarded the court’s

admonition to not conduct any extra-judicial investigation; and (5) the court

erred in not taking judicial notice of Friedman’s second amended complaint.

On August 12, 2024, Stabosz filed an Amended Statement in Opposition to the

Motion to Correct Error.

[4] On August 22, 2024, the court held a hearing on the motion. Thirty-five days

later, on September 26, 2024, the trial court entered an order denying Friedman

relief on four of the requested grounds but granting Friedman’s Motion to

Correct Error on one ground and vacating the jury verdict entered on June 28,

1 Justices Massa and Slaughter voted to grant the petition to transfer.

Court of Appeals of Indiana | Opinion 24A-PL-2536 | December 22, 2025 Page 3 of 16 2024. 2 Specifically, the court determined that it committed reversible error in

failing to give the version of Final Instruction No. 8 as the court had initially

agreed to give at the time of the final instruction conference, and that the

appropriate remedy was to grant a new trial.

[5] On October 2, 2024, Stabosz filed a Motion for Relief pursuant to Ind. Trial

Rule 60. Stabosz argued that pursuant to Ind. Trial Rule 53.3(A), Friedman’s

Motion to Correct Error was deemed denied due to the court’s failure “to rule

on [the] Motion to Correct Error within thirty (30) days after it was heard[.]”

Appellant’s Appendix Volume II at 163. Accordingly, Stabosz asserted that the

court’s September 26, 2024 order was void because it was entered more than

thirty days after the hearing on the motion. On October 3, 2024, the court

granted Stabosz’s Motion For Relief, therein ordering that the court’s

September 26, 2024 order “is hereby rescinded.” Id. at 168. Also on October 3,

2024, Friedman filed a Response in Opposition to Motion for Relief, and on

October 4, 2024, Friedman filed a Motion to Reconsider Order of October 3,

2024.

[6] On October 11, 2024, the court issued an order vacating its October 3, 2024

order and reinstating its September 26, 2024 order granting Friedman’s Motion

to Correct Error, vacating the jury verdict, and ordering a new trial. Stabosz

2 Although the September 26, 2024 order states that the hearing on the Motion to Correct Error occurred on August 27, 2024, both parties acknowledge, and the Chronological Case Summary reflects, that the hearing did, in fact, occur on August 22, 2024.

Court of Appeals of Indiana | Opinion 24A-PL-2536 | December 22, 2025 Page 4 of 16 filed a Notice of Appeal on October 17, 2024, and an amended-Notice of

Appeal on November 12, 2024.

Discussion

I.

[7] Stabosz asserts that the trial court’s belated grant of Friedman’s Motion to

Correct Error is a nullity, or “at a minimum, that it is void.” Appellant’s Brief

at 20. Generally, we review the grant or denial of a motion to correct error for

an abuse of discretion. Indianapolis Pub. Transportation Corp. v. Bush, 266 N.E.3d

719, 726 (Ind. 2025). That is to say, we will only reverse where the trial court’s

judgment is clearly against the logic and effect of the facts and circumstances

before it or where the trial court errs on a matter of law. Berg v. Berg, 170

N.E.3d 224, 227 (Ind. 2021). A trial court exceeds its discretion when its

decision is unlawful, illogical, or otherwise unreasonable. Expert Pool Builders,

LLC v. Vangundy, 224 N.E.3d 309, 312 (Ind. 2024).

[8] Motions to correct error are governed by Ind. Trial Rule 53.3. Wurster Const.

Co. v. Essex Ins. Co., 918 N.E.2d 666, 671 (Ind. Ct. App. 2009). Specifically, the

rule provides:

In the event a court fails for forty-five (45) days to set a Motion to Correct Error for hearing, or fails to rule on a Motion to Correct Error within thirty (30) days after it was heard or forty-five (45) days after it was filed, if no hearing is required, the pending Motion to Correct Error shall be deemed denied. Any appeal shall be initiated by filing the notice of appeal under Appellate Rule 9(A) within thirty (30) days after the Motion to Correct Error is deemed denied. Court of Appeals of Indiana | Opinion 24A-PL-2536 | December 22, 2025 Page 5 of 16 Ind. Trial Rule 53.3(A). Regarding the “deemed denied” language, we have

explained that “[t]his denial is automatic; it is ‘self-activating upon the passage

of the requisite number of days.’” Wurster, 918 N.E.2d at 671 (citations

omitted).

[9] The Indiana Supreme Court has recognized when a trial court purports to grant

a motion to correct error belatedly, that is, after the expiration of the thirty-day

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