University of Notre Dame v. Carol H. Bahney

CourtIndiana Court of Appeals
DecidedOctober 27, 2020
Docket20A-CT-219
StatusPublished

This text of University of Notre Dame v. Carol H. Bahney (University of Notre Dame v. Carol H. Bahney) 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
University of Notre Dame v. Carol H. Bahney, (Ind. Ct. App. 2020).

Opinion

FILED Oct 27 2020, 8:51 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

ATTORNEY FOR APPELLANT ATTORNEY FOR APPELLEE James F. Groves Ann Marie Waldron Lee, Groves and Zalas Waldron Law, LLC South Bend, Indiana Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

University of Notre Dame, October 27, 2020 Appellant-Defendant, Court of Appeals Case No. 20A-CT-219 v. Appeal from the St. Joseph Superior Court Carol H. Bahney, The Honorable Appellee-Plaintiff Steven L. Hostetler, Judge Trial Court Cause No. 71D07-1612-CT-545

Vaidik, Judge.

Case Summary [1] Carol H. Bahney sued the University of Notre Dame after she fell at a

basketball game. A jury found Bahney primarily at fault for the fall and

returned a verdict for Notre Dame. Bahney then moved for a new trial under

Indiana Trial Rule 60(B)(3) based primarily on Notre Dame’s failure to notify

Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 1 of 17 her before trial that a Notre Dame employee had testified incorrectly at a

deposition. The trial court granted Bahney’s motion and ordered a new trial.

We reverse.

Facts and Procedural History [2] On December 13, 2014, Bahney and some friends were at the Purcell Pavilion

on Notre Dame’s campus to watch a Notre Dame women’s basketball game.

While walking on the wooden floor behind one of the baskets, Bahney tripped

and fell onto a four-to-five-inch riser that was set up in front of the stands at the

end of the court. As a result, she broke her shoulder.

[3] Two years later, Bahney sued Notre Dame, alleging that it “negligently failed to

maintain a safe and unobstructed floor” and “failed to warn plaintiff of the

floor’s defective condition[.]” Appellant’s App. Vol. II p. 18. Shortly thereafter,

Notre Dame’s attorney had photographs taken of the area of the fall and

provided them to Bahney. The following photograph shows the riser (the white

platform):

Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 2 of 17 Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 3 of 17 Ex. 3. At a deposition in September 2017, Joyce Harmon—who was at the

game with Bahney and who was walking in front of Bahney when she fell—was

asked about the photograph. She testified that it accurately depicted the riser

but that the tables and chairs were not on the riser at the time of the fall. She

suspected that Bahney did not see the riser and tripped over it. (Bahney herself

could not recall much about the incident, so Harmon was her primary liability

witness.)

[4] Trial was eventually scheduled to begin on November 20, 2019. At a deposition

held two weeks before trial, Notre Dame Associate Athletic Director Monica

Cundiff testified that she believed the tables and chairs were on the riser when

Bahney fell, as depicted in the photograph. After the deposition, Notre Dame’s

attorney ask Cundiff if there was any way she could confirm that there were

tables and chairs on the riser when Bahney fell. Cundiff found video of the

game on YouTube and saw “that the tables weren’t there.” Tr. Vol. III p. 39. At

some point before trial, Cundiff relayed this information to Notre Dame’s

attorney, explaining that “sometimes during a women’s game they don’t have

the table” because “there aren’t as many press for a women’s game as for men.”

Id.; see also Appellant’s Br. p. 7. However, Notre Dame’s attorney did not relay

this information to Bahney.

[5] The jury trial began as scheduled on November 20. Bahney’s theory (as detailed

in her opening statement) was that

the riser wasn’t marked other than having some little yellow tape around it. It’s very low to the ground, not very easily seen,

Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 4 of 17 nothing to draw attention to it, no signs, watch your step, no one there saying watch your step. Nothing to warn them that this riser is there and is a tripping hazard.

Tr. Vol. II p. 41. Harmon again testified that there were no tables on the riser

when Bahney fell. She clarified that there were some chairs but said they were

“way back” on the riser (not at the front of the riser, as depicted in the

photograph). Id. at 106. She also stated her belief that Bahney had tripped on

the riser.

[6] Notre Dame’s sole witness was Cundiff. To Bahney’s surprise, Cundiff testified

that her deposition testimony was incorrect because the photograph actually

depicted the setup for a men’s basketball game and, for the women’s game at

issue, there were no tables where Bahney fell and “the chairs would have been

pushed back.” Id. at 230. She acknowledged that the tables and chairs being on

the riser as depicted in the photograph would provide “a visual cue three or four

feet off the ground that someone walking in this area can’t just continue to walk

forward, you’re going to have to go to around this riser[.]” Id. at 229.

Nonetheless, the jury found Bahney 90% at fault and returned a verdict for

Notre Dame.

[7] A month later, Bahney filed a motion that was labeled as a motion to correct

error under Indiana Trial Rule 59 but that was otherwise framed as a motion for

relief from judgment under Indiana Trial Rule 60(B)(3), which allows a trial

court to set aside a judgment based on “misconduct of an adverse party.”

Bahney argued that Notre Dame was required by Trial Rule 26(E) to

Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 5 of 17 “seasonably” amend Cundiff’s incorrect deposition testimony. She alleged that

had Notre Dame done so she “could have focused on other issues such as the

markings on the risers or other warnings rather than wasting time on what were

actually unnecessary issues” and “a supplemental request could have been

made for accurate pictures of the set up for a women’s basketball game.”

Appellant’s App. Vol. II pp. 44-45. Bahney asserted that “[t]his inability to

focus on the true issues at trial prevented Bahney from ‘fully and fairly’

presenting her case and did cause her prejudice.” Id. at 45.

[8] After a hearing, the trial court issued an order granting Bahney’s motion and

vacating the judgment. The court said it was “a very close call” but ultimately

concluded that Notre Dame failed to comply with Trial Rule 26(E) and that this

“noncompliance likely interfered to some extent with the case Ms. Bahney

would otherwise have presented.” Id. at 15-16.

[9] Notre Dame now appeals.

Discussion and Decision [10] Notre Dame contends that the trial court erred by setting aside the judgment

and ordering a new trial under Trial Rule 60(B)(3). It first argues that the trial

court should have treated Bahney’s motion as a motion to correct error under

Trial Rule 59, as Bahney labeled it, rather than as a motion for relief from

judgment under Rule 60(B)(3), and that Bahney did not satisfy the requirements

of Rule 59. But as noted above, notwithstanding the title and the first sentence,

Court of Appeals of Indiana | Opinion 20A-CT-219 | October 27, 2020 Page 6 of 17 the motion was in substance a motion under Rule 60(B)(3). See id. at 40-45.

Rule 60(B)(3) provides that a trial court may relieve a party from a judgment

based on fraud, misrepresentation, “or other misconduct of an adverse party[.]”

Bahney’s motion accused Notre Dame of “misconduct,” expressly invoked

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