Scott Haywood and Carin Haywood (AKA Carin Price) DBA Haywood's Auto Sales & Service v. Circle Distributing, Inc. (mem. dec.), 67A01-1603-CC-701

Haywood’s Auto (Scott and Carin Haywood) had a credit agreement with Circle Distributing for auto parts; payments became delinquent and Circle sued for breach, unjust enrichment, and failure to pay.
Bench trial was set for Jan 20, 2016; Haywood’s Auto filed a continuance motion Jan 19 citing a winter weather advisory that might prevent counsel and an essential witness from attending.
The trial court indicated it was not inclined to grant the continuance; on the morning of trial Haywood’s counsel, the witness, and the Haywoods did not appear. Circle and the court attended despite similar travel conditions.
Trial proceeded in absentia and judgment entered for Circle. Haywood’s Auto subsequently filed a motion to reconsider/continuance, a motion to correct error, and a Trial Rule 60(B) motion, attaching affidavits describing icy roads and emergency towing calls that prevented attendance.
The trial court denied relief; on appeal the Court of Appeals reviewed only whether the denial of the continuance (via denial of the motion to correct error) was an abuse of discretion and affirmed.
Judge Riley dissented, arguing the weather advisory and emergency towing obligations constituted good cause and the absence prevented an important witness from testifying, making denial an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Haywood’s Auto’s motion for continuance (and thus denying the motion to correct error)	Weather advisory and affidavits showed good cause; counsel and essential witness iced in; emergency towing obligations prevented attendance	Trial court reasonably found no good cause: court and opposing party attended despite conditions, local schools open with delay, and Haywood’s Auto did not make arrangements	No abuse of discretion; denial affirmed (majority). Dissent would find abuse of discretion based on hazardous conditions and emergency duties

Williamson v. Williamson, 825 N.E.2d 33 (Ind. Ct. App. 2005) (trial court has broad discretion to decide motions to correct error)
Hess v. Hess, 679 N.E.2d 153 (Ind. Ct. App. 1997) (decision to grant or deny continuance is within trial court discretion)
J.P. v. G.M., 14 N.E.3d 786 (Ind. Ct. App. 2014) (abuse-of-discretion standard for trial rulings)
Verta v. Pucci, 14 N.E.3d 749 (Ind. Ct. App. 2014) (review of continuance and trial-court discretion)
Walker v. Kelley, 819 N.E.2d 832 (Ind. Ct. App. 2004) (definition of abuse of discretion)
Scott v. Crussen, 741 N.E.2d 743 (Ind. Ct. App. 2000) (moving party must be free from fault and show likely prejudice from denial of continuance)
Danner v. Danner, 573 N.E.2d 934 (Ind. Ct. App. 1991) (same principle regarding continuances)
Blackford v. Boone County Area Plan Com’n, 43 N.E.3d 655 (Ind. Ct. App. 2015) (continuance granted only upon showing good cause)
Gunashekar v. Grose, 915 N.E.2d 953 (Ind. 2009) (continuance standard and abuse-of-discretion review)
Flick v. Simpson, 252 N.E.2d 508 (Ind. Ct. App. 1969) (unavoidable absence is good cause but denial is not error if party fails to show sufficient reason)