Putnam County Sheriff v. Price, 954 N.E.2d 451

Pamela Price was injured when her vehicle hit an icy condition on County Road 375 West in Putnam County, Indiana.
Earlier that morning, another driver lost control at the same location; a sheriff deputy notified the highway department but no corrective action was taken.
The Reelsville Water Authority had investigated a water line leak that caused water to run across and freeze on the roadway but did not repair or warn about the ice.
Price sued the Sheriff, the Highway Department, the Board of Commissioners, and the Water Authority for negligence.
The Sheriff moved to dismiss, arguing no duty to warn or alleviate road hazards and immunity under ITCA; the trial court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sheriff owed a common law duty to warn of hazards on a county road they do not own or control	Price relies on Benton to assert a duty to warn.	Sheriff has no duty absent ownership, maintenance, or control; may be immune under ITCA.	No duty found; Sheriff not negligent as a matter of law.

Benton v. City of Oakland City, 721 N.E.2d 224 (Ind. 1999) (limits on sovereign immunity; duty to exercise ordinary care)
Hochstetler v. Elkhart Cnty. Highway Dep't, 868 N.E.2d 425 (Ind.2007) (governmental duty to keep roads reasonably safe)
Bules v. Marshall Cnty., 920 N.E.2d 247 (Ind.2010) (duty to warn of hazardous road conditions when responsible for premises)
Dzierba v. City of Michigan City, 798 N.E.2d 463 (Ind.Ct.App.2003) (land ownership/control required to remedy hazards)
Campbell v. State, 259 Ind. 55, 284 N.E.2d 733 (Ind.1972) (relevance of Campbell to duty when sovereign immunity is abolished)