Citizens Action Coalition of Indiana, Energy Policy Institute, and Common Cause of Indiana v. Eric Koch, and Indiana House Republican Caucus, 51 N.E.3d 236

Energy and Policy Institute (with Citizens Action Coalition and Common Cause) made three APRA requests to Rep. Eric Koch seeking communications with energy businesses about legislation; Chief Counsel of House Republican Caucus denied them.
Public Access Counselor issued advisory opinions: APRA applies to the General Assembly but much of the requested material may be discretionary "work product."
Plaintiffs sued for declaratory relief that APRA applies and that defendants unlawfully withheld records; sought disclosure of nonexempt records.
Defendants moved to dismiss for lack of justiciability (T.R. 12(B)(1)) and, alternatively, failure to state a claim (T.R. 12(B)(6)). Trial court dismissed for non-justiciability; supreme court granted transfer.
Supreme Court held it has jurisdiction and that APRA generally applies to the General Assembly and its members, but declined to decide whether the specific requested documents are exempt as legislative "work product," finding that question non-justiciable under separation-of-powers principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Supreme Court have jurisdiction to hear the appeal?	Plaintiffs sought review and emergency transfer under Appellate Rule 56(A).	Defendants argued trial court properly dismissed for lack of jurisdiction/justiciability.	Court has subject-matter jurisdiction (Rule 56 transfer proper).
Does APRA apply to the Indiana General Assembly and its members?	APRA governs public agencies; General Assembly is a public agency and APRA contemplates legislative application.	Caucus argued APRA does not apply to the legislature.	APRA applies to the General Assembly and its members.
Are the specific requested documents exempt as legislative "work product," and is that question justiciable?	Plaintiffs asked court to define scope and order disclosure of nonexempt records.	Defendants argued disclosure would interfere with internal legislative functions and is discretionary under APRA.	Whether particular records fall within the legislative work-product exception is non-justiciable; court will not define "work product" for the legislature.
Was dismissal appropriate given procedural posture (T.R. 12(B)(1)/(6))?	Plaintiffs contended dismissal was premature; factual development needed.	Defendants relied on non-justiciability and alternative dismissal grounds (standing, agency status).	Trial court erred to dismiss for lack of jurisdiction, but dismissal is affirmed on non-justiciability grounds (T.R.12(B)(6) affirmation).

State ex rel. Masariu v. Marion Superior Court No. 1, 621 N.E.2d 1097 (Ind. 1993) (courts must avoid inquiries that interfere with internal legislative operations)
Berry v. Crawford, 990 N.E.2d 410 (Ind. 2013) (distinguishes jurisdiction from prudential justiciability under separation of powers)
McPeek v. McCardle, 888 N.E.2d 171 (Ind. 2008) (appellate court may affirm dismissal on any sustainable theory)