Diamond Quality, Inc. v. Dana Light Axle Products, LLC
1:22-cv-00114
N.D. Ind.Jun 11, 2025Background
- Diamond Quality, Inc. ("Diamond") is an inspection/sorting company that provided industrial services to Dana Light Axle Products, LLC ("Dana Fort Wayne") and related subsidiaries, earning over $1.5 million since 2014.
- Diamond was contracted by Dana’s Mexican suppliers (Dana AMSA and Dana ETRAC) to perform sorting on parts at the Dana Fort Wayne facility to determine responsibility for non-conforming parts.
- In 2019, Dana Fort Wayne decided to reduce the use of third-party sorting companies including Diamond, allegedly for cost-cutting; Diamond claimed this was to push costs on suppliers.
- After being excluded in 2019, Diamond was designated by Dana ETRAC and AMSA to do 2020 sorting jobs at Dana Fort Wayne but was refused entry by Dana Fort Wayne, which used a different sorting company.
- Diamond sued Dana Fort Wayne for tortious interference with contractual and business relationships, arguing exclusion from the property was unjustified.
- The Indiana Supreme Court was asked whether property owners act without justification by barring entry, and answered that (absent contract/statute) the owner always has the right to exclude; this decided the case in Dana’s favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether excluding Diamond from Dana's property was unjustified, supporting a tortious interference claim | Exclusion was an unjustified act disrupting contracts | Owner has absolute right to exclude absent contract/statute | Exclusion is justified per se unless owner obligated otherwise |
| Whether contracts between Diamond and third parties gave right to enter Dana’s property | Contracts with suppliers confer right to enter | No contract between owner and entrant; no entry right | No right to enter without owner-entrant contract |
| Whether any statutory right permitted Diamond’s entry | Implied or general statutory right exists | No statutory right alleged or proven | No statutory right; statutory exceptions inapplicable |
| Whether Dana’s conduct can be wrongful absent contractual/statutory duty | Dana’s actions were wrongful interference | Property law principles permit exclusion | Exercise of exclusion right not wrongful under state law |
Key Cases Cited
- Diamond Quality, Inc. v. Dana Light Axle Products, LLC, 256 N.E.3d 529 (Ind. 2025) (holding that, absent a contractual or statutory duty, property owners are always justified in excluding others from their premises)
- Coleman v. Vukovich, 825 N.E.2d 397 (Ind. Ct. App. 2005) (identifying lack of justification as an element of tortious interference)
- McCollough v. Noblesville Schools, 63 N.E.3d 334 (Ind. Ct. App. 2016) (discussing elements of tortious interference under Indiana law)