Indiana Ass'n of Beverage Retailers, Inc. v. Indiana Alcohol & Tobacco Commission, 945 N.E.2d 187

IABR sued to enjoin the Indiana Alcohol and Tobacco Commission from issuing beer dealer permits under alleged quota violations.
Title 7.1 governs alcoholic beverage regulation; Article 3 sets permit types and recipients, with quotas in Chapter 22.
Statutes distinguish beer dealer permits, liquor dealer permits, and package liquor store permits; some permits are counted against specific quotas.
Commission historically counted permits by type (beer, liquor, package store) rather than across combined categories; IABR challenges this method as miscounting against quotas.
Trial court held Article 3 is ambiguous; Commission's three-quota interpretation is reasonable and enforceable; per se irreparable harm not shown.
On appeal, court affirmed denial of TRO and preliminary injunction, concluding Commission’s interpretation is reasonable and lawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion denying the preliminary injunction	IABR contends quotas are misapplied, violating 7.1-3-22-4 and blocks new permits unlawfully.	Commission's three-quota interpretation is reasonable and deference due to agency expertise; no clear statutory violation.	No abuse; interpretation reasonable, injunction denied.

Wyatt v. Wheeler, 936 N.E.2d 232 (Ind.Ct.App.2010) (per se injunction when unlawful conduct is clear, but public interest matters still considered)
Indiana Family & Soc. Serv. Admin. v. Walgreens Co., 769 N.E.2d 158 (Ind.2002) (per se rule proper only when statute violation is clear)
Pendleton v. Aguilar, 827 N.E.2d 614 (Ind.Ct.App.2005) (statutory interpretation de novo; ambiguity triggers agency deference)
LTV Steel Co. v. Griffin, 730 N.E.2d 1251 (Ind.2000) (read statutes in their plain sense and harmonize when possible)
Fraley v. Minger, 829 N.E.2d 476 (Ind.2005) (judicial interpretation of statutes with legislative acquiescence considerations)