Eagle Aircraft, Inc. v. Anthony Trojnar
2013 Ind. App. LEXIS 104
Ind. Ct. App.2013Background
- Trojnar prepaid funds with Eagle Aircraft for flight accounts totaling $1,855.88; he sought refund after requesting closure of his account; Eagle Aircraft offered a contract-based refund policy (Exhibit A) and other rental documents; at trial, Eagle Aircraft relied on Exhibit A but Trojnar testified he met ext ext circumstances to justify a refund; the court took Eagle’s Rule 41(B) motion under advisement and later awarded Trojnar $1,855.88 plus interest; after hearings on correction of errors, the court amended the judgment to $1,755.88 and costs, crediting $100 per Exhibit D; the court concluded Exhibit A governs the parties’ relationship, with extenuating circumstances allowing a refund; on appeal, the court affirmed the amended judgment, rejecting unjust enrichment as a basis for reducing the award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 41(B) motion deprived Eagle of presenting evidence | Eagle relied on documentary exhibits; court invited evidence | 41(B) applied; movant should be able to present defense | No reversible error; court invited evidence and 41(B) not denied opportunity |
| Whether the court erred in Trojnar’s favor based on contract interpretation | Exhibit A unambiguously nonrefundable; court relied on it | Exhibit A applies with extenuating circumstances; trial court weighed evidence | Court properly ruled in Trojnar’s favor under ext ext circumstances |
| Whether Trojnar was unjustly enriched by the court’s order | Award should reflect non-refunded credits under contract | Unjust enrichment not applicable due to contract governs remedy | Unjust enrichment not warranted; contract controls and remedies at law; affirmed |
Key Cases Cited
- Redmond v. United Airlines, Inc., 165 Ind. App. 395, 332 N.E.2d 804 (Ind. Ct. App. 1975) (discussion of post-motion evidence after 41(B) denial)
- Smith v. Markun, 124 Ind. App. 535, 119 N.E.2d 899 (Ind. Ct. App. 1954) (timely request to present evidence after motion denial)
- Beckman v. Communications Workers Union, 540 N.E.2d 117 (Ind. Ct. App. 1989) (court invited rebuttal evidence after 41(B) motion; preserved right to present evidence)
- LTL Truck Serv., LLC v. Safeguard, Inc., 817 N.E.2d 664 (Ind. Ct. App. 2004) (41(B) applicable to small claims proceedings; interaction with Small Claims Rules)
- Brown v. Guinn, 970 N.E.2d 192 (Ind. Ct. App. 2012) (41(B) denial not error in small claims context)