Rowe v. Indiana Department of Correction, 940 N.E.2d 1218

Rowe was incarcerated at Pendleton Correctional Facility and transferred to Indiana State Prison on March 2, 2010.
Items allegedly missing during the move included a fan, a hot pot, and headphones; ISP inventory recorded the missing items.
Rowe filed a small claims action on July 26, 2010 seeking return or compensation of $74.76 for the missing items.
On the same day, Rowe petitioned for an order waiving all or part of filing fees and court costs based on financial hardship.
The trial court denied the petition on August 18, 2010 and warned of dismissal if the fee was not paid.
Rowe appealed October 18, 2010 challenging the denial of the fee waiver petition, asserting interlocutory appeal rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is an interlocutory appeal as of right under Appellate Rule 14(A).	Rowe relies on 14(A)(1) money-jump; argues payment/amount-order.	No money-pay order; not a final or expressly appealable interlocutory order.	Not an interlocutory appeal as of right; appeal dismissed for lack of jurisdiction.

State v. Hogan, 582 N.E.2d 824 (Ind. 1991) (payment-of-money concept for appealability discussed)
National Gen. Ins. Co. v. Riddell, 705 N.E.2d 465 (Ind.Ct.App.1998) (examples of 'payment of money' within App. R. 14(A)(1) framework)
Schwedland v. Bachman, 512 N.E.2d 445 (Ind.Ct.App.1987) (deposits to court and similar orders cited as payment-like)
Estate of Meyer, 702 N.E.2d 1078 (Ind.Ct.App.1998) (death-taxes orders cited in 'payment of money' context)
Skiles v. Skiles, 646 N.E.2d 353 (Ind.Ct.App.1995) (attorney's fees as payment-like sanctions cited)
Lamon v. Lamon, 611 N.E.2d 154 (Ind.Ct.App.1993) (child-support payments cited in appealability context)
State v. Kuespert, 425 N.E.2d 229 (Ind.Ct.App.1981) (sanctions/fee-related orders discussed)
Moser v. Moser, 838 N.E.2d 532 (Ind.Ct.App.2005) (interlocutory appeal jurisdiction; dismissal for lack of jurisdiction)