Cynthia Morrison, individually and on behalf of Ernest Morrison v. Ricardo Vasquez, M.D. Indiana University Health Southern Indiana Physicians, Inc. v. Charlene Noel, 124 N.E.3d 1217

Two consolidated Indiana cases (Morrison and Noel) question whether a defendant organization's "principal office" for Trial Rule 75(A)(4) is the address of its registered agent in Indiana or its actual principal executive office.
Morrison: plaintiff sued in Marion County; defendants moved to transfer to Monroe County where defendant health system maintains its principal office; trial court and Court of Appeals granted transfer.
Noel: plaintiff sued in Marion County (based on defendants' registered-agent addresses); trial court and Court of Appeals denied defendants' motion to transfer to Lawrence County.
Earlier precedent (American Family; CTB) treated the registered-agent/registered-office address as the corporation's principal office for venue, particularly for foreign corporations.
In 2018 Indiana revised corporation statutes: defined "principal office" as the principal executive office and enacted § 23‑0.5‑4‑12 stating a registered agent's address does not determine venue.
The Supreme Court consolidated the cases to resolve the conflict and decide whether the statutory changes displace the registered-agent rule for venue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the county of a domestic corporation's registered agent is the "principal office" for Trial Rule 75(A)(4) venue	Morrison/Noel: Marion County is preferred because defendants' registered agents are located there	Defendants: "principal office" is the corporation's actual principal executive office (Monroe/Lawrence), not the registered agent's address	Held: For domestic organizations, "principal office" means the actual principal executive office; registered-agent address does not determine preferred venue
Whether 2018 business-organization statutes that redefine "principal office" and limit venue effect are applicable and controlling (including retroactivity)	Plaintiffs: American Family/CTB control; the new statute is ineffective or not retroactive to filings before Jan 1, 2018	Defendants: New statutes apply, are procedural, and govern venue determination after enactment	Held: The 2018 statutes apply to both domestic and foreign entities, are procedural and applicable here, and displace the registered-agent rule; statutes do not conflict with Trial Rule 75 and control the meaning of "principal office"

American Family Ins. Co. v. Ford Motor Co., 857 N.E.2d 971 (Ind. 2006) (adopted registered-office-as-principal-office rule for venue—primarily applied to foreign corporations)
CTB, Inc. v. Tunis, 95 N.E.3d 185 (Ind. Ct. App. 2018) (applied American Family to a domestic corporation without distinguishing facts)
Randolph County v. Chamness, 879 N.E.2d 555 (Ind. 2008) (explains purposes and benefits of preferred-venue rules)
Ind. Bureau of Motor Vehicles v. Watson, 70 N.E.3d 380 (Ind. Ct. App. 2017) (procedural statutes may be applied retroactively)
Garner v. Kempf, 93 N.E.3d 1091 (Ind. 2018) (principle that court rules govern when conflict exists between rules and statutes)