Hood's Gardens, Inc. v. Jason Young, Craig Meade d/b/a Discount Tree Excavation a/k/a D & E Tree Extraction
2012 Ind. App. LEXIS 432
| Ind. Ct. App. | 2012Background
- HG filed a declaratory judgment action to determine if HG could be secondarily liable for Young's workers' compensation benefits under IC 22-3-2-14(b) due to a contract between HG and D&E for tree removal.
- HG alleged D&E did not have workers' compensation coverage and that Young might pursue a claim against D&E, potentially making HG liable under secondary-liability provisions.
- D&E (owner Mead) contracted to remove a tree; Young was injured while removing the remainder on HG’s property.
- Young later sought workers’ compensation benefits; HG sought a judicial construction of its potential liability under the statute.
- The trial court dismissed the action for lack of subject-matter jurisdiction, citing exclusive board jurisdiction under the Workers’ Compensation Act; HG appealed.
- The Board had stayed proceedings pending resolution of the declaratory judgment action; HG sought summary judgment that no secondary-liability basis existed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court had jurisdiction to decide secondary-liability under the Act | HG contends DJA may resolve whether contract value triggers secondary liability | Young argues Board has exclusive jurisdiction over workers’ compensation issues | Trial court erred; DJA jurisdiction proper for contract-interpretation issue |
| Whether the exclusivity provision deprives courts of core jurisdiction | Exclusivity does not preclude threshold contract construction | Exclusivity limits all remedies, including threshold determinations | Exclusivity did not bar the trial court from addressing the contract-valuation issue under DJA |
| Whether the DJA is an appropriate vehicle to resolve the dispute | DJ A offers a just, economical means to determine exposure before Board action | DJ A may be unnecessary if Board has exclusive jurisdiction | DJ A is appropriate to determine whether contract value effects liability and to resolve the entire controversy |
Key Cases Cited
- Hatke v. Fiddler, 868 N.E.2d 60 (Ind. Ct. App. 2007) (standard for reviewing lack-of-subject-matter jurisdiction on appeal depends on trial record)
- GKN Co. v. Magness, 744 N.E.2d 397 (Ind. 2001) (de novo standard for subject-matter jurisdiction on paper records)
- Williams v. R.H. Marlin, Inc., 656 N.E.2d 1145 (Ind. Ct. App. 1995) (exclusivity provision may deprive trial courts of jurisdiction)
- Ember v. Ember, 720 N.E.2d 436 (Ind. Ct. App. 1999) (Uniform Declaratory Judgment Act purpose and remedy)
- Madden v. Hauck, 403 N.E.2d 1133 (Ind. Ct. App. 1980) (Declaratory judgments serve a useful purpose when resolving rights)
- Boone County Area Plan Comm’n v. Kennedy, 560 N.E.2d 692 (Ind. Ct. App. 1990) (Declaratory judgment test: usefulness and efficiency in resolving controversy)
- Ferrell v. Dunescape Beach Club Condominiums Phase I, Inc., 751 N.E.2d 702 (Ind. Ct. App. 2001) (Declaratory relief should resolve the problem and be economical)