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Mary Rawle v. Charles Bowman

2026-08-31

Summary

Holding. The trial court abused its discretion by granting default judgment against the defendants because the motion to dismiss, though filed late, was a valid responsive pleading that remained pending before the court. Additionally, the trial court lacks personal jurisdiction over Rawle, Montgomery McCracken, and Powell due to insufficient minimum contacts with Indiana. The judgment is reversed and remanded with instructions to dismiss the claims against Rawle, Montgomery McCracken, and Powell, while remanding the claim against the Center for further proceedings.

Bowman, an Indiana Gestalt therapy practitioner, sued in state court after the Center for Gestalt Development and its representatives pursued copyright claims against him in Pennsylvania federal court. Bowman alleged abuse of process, malicious prosecution, and intentional infliction of emotional distress. The defendants filed a motion to dismiss challenging personal jurisdiction and failure to state a claim. When the case was later removed to federal court, jurisdiction was suspended. After remand to state court, the trial court eventually granted Bowman's motion for default judgment, concluding the defendants had waived their defenses by not answering within required deadlines.

The appellate court reversed, holding that the trial court abused its discretion in granting default judgment. Although the defendants' motion to dismiss was filed after the initial deadline, it constituted a valid responsive pleading under Indiana law and remained pending before the court when default was requested. The court further determined it lacked personal jurisdiction over three of the four defendants—Rawle, Powell, and Montgomery McCracken—because they had insufficient minimum contacts with Indiana and their alleged conduct was directed at Pennsylvania, not Indiana.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a motion to dismiss filed after the answer deadline constitutes a valid responsive pleading that avoids default judgment
  • Whether a trial court may grant default judgment when a defendant's motion remains pending before it
  • Whether Indiana courts have personal jurisdiction over out-of-state defendants who directed their allegedly wrongful conduct at another state
  • Whether an attorney and law firm hired to pursue claims in another state have sufficient minimum contacts with Indiana through their client's alleged conduct

Procedural posture

Appeal from a trial court's grant of default judgment in Bowman's favor against the defendants in state court tort claims arising from copyright litigation in Pennsylvania federal court.

Authorities cited

Opinion

majority opinion

IN THE

Court of Appeals of Indiana

Mary Rawle, The Center for Gestalt Development, Inc., John J.

Powell, and Montgomery McCracken Walker & Rhoads, LLP,

Appellants-Defendants FILED

Aug 31 2026, 9:16 am

v. CLERK

Indiana Supreme Court

Court of Appeals

and Tax Court

Charles Bowman,

Appellee-Plaintiff

August 31, 2026

Court of Appeals Case No.

25A-PL-2715

Appeal from the Hamilton Superior Court

The Honorable David K. Najjar, Judge

The Honorable A.J. Johnson, Magistrate

Trial Court Cause No.

29D05-2207-PL-5477

Opinion by Judge Kenworthy

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 1 of 26

Judges Bradford and Pyle concur.

Kenworthy, Judge.

Case Summary

[1] In May 2021, the Center for Gestalt Development (the “Center”) sued Charles

Bowman in Pennsylvania federal court alleging infringement of an exclusive

license to publish certain copyrighted materials on Gestalt therapy. About four

months later, the Center dropped the lawsuit. Then, in May 2022, the Center

once more filed suit in Pennsylvania federal court, alleging infringement of its

copyright. Attorney John Powell of the Pennsylvania law firm Montgomery

McCracken Walker & Rhoads, LLP (“Montgomery McCracken”) represented

the Center in the second district court action.

[2] On July 22, 2022, Bowman filed a complaint in the Hamilton Superior Court

against the Center; the Center’s president, Mary Rawle; Powell; and

Montgomery McCracken (collectively, “Defendants”) on several tort claims

alleging malfeasance in Defendants’ pursuit of the Pennsylvania actions.

Defendants filed a notice of removal to Indiana federal court on August 16.

While in district court, Bowman stipulated he was not seeking damages greater

than $75,000, so his lawsuit was remanded to Indiana state court on December

30.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 2 of 26 [3] On January 23, 2023, Defendants moved to dismiss Bowman’s lawsuit,

challenging personal jurisdiction and arguing failure to state a claim for relief.

Bowman moved for default judgment on December 17, 2024. On September

15, 2025—with the motion to dismiss still pending—the trial court granted

Bowman’s motion for default judgment. Defendants filed a motion to correct

error, which the court denied.

[4] Defendants raise a number of issues for appellate review, which we consolidate

and restate as:

1. Did the trial court err in granting default judgment against

Defendants?

2. Did the trial court have personal jurisdiction over

Defendants?

[5] We first hold the trial court abused its discretion by granting default judgment

against Defendants. We then conclude the trial court lacks personal jurisdiction

over Rawle, Montgomery McCracken, and Powell.

[6] We reverse and remand with instructions.

Facts and Procedural History

[7] Bowman is a practitioner of Gestalt therapy in Indiana. In 2019, he published a

book titled Psychopathology of Awareness, which contained a previously

unpublished manuscript by Dr. Frederick Perls, the widely recognized founder

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 3 of 26

of Gestalt therapy. 1 In May 2021, the Center sued Bowman in the Eastern

District of Pennsylvania over the publication, claiming the exclusive right to

publish Dr. Perls’ manuscript under copyright law. The parties engaged in

settlement talks after the Center voluntarily dropped the lawsuit. But no

settlement materialized. In May 2022, the Center filed a second action in

Pennsylvania federal court, seeking damages for the alleged copyright

violation. 2

[8] On July 22, Bowman sued Defendants in Indiana state court, alleging abuse of

process, malicious prosecution, intentional infliction of emotional distress, and

civil conspiracy. 3 The complaint maintained Rawle and the Center caused

service of process to be issued against Bowman, and that the sole purpose of the

Center’s claims in Pennsylvania had been to extort money from him. More

specifically, Bowman alleged Rawle and the Center investigated the value of his

home in Indiana and hired local counsel, E. Victor Indiano, to coerce him into

a settlement. Bowman included excerpts from a demand letter Indiano drafted,

which the complaint described as filled with “highly intrusive personal

information that was totally irrelevant” to the claims the Center filed in

Pennsylvania federal court. Appellants’ App. Vol. 2 at 31. Bowman further

1

Bowman published the book as co-editor alongside French resident and fellow practitioner, Jean-Marie

Robine. The book was published in France under the auspices of the Institut Français de Gestalt-Thérapie.

2

The Pennsylvania federal court dismissed the Center’s suit for improper venue and lack of personal

jurisdiction in October.

3

The complaint included a fifth count claiming pecuniary losses, which Bowman subsequently withdrew.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 4 of 26

claimed each of the named defendants conspired “to initiate [f]rivolous”

lawsuits and were each “equally liable for the other’s wrongful actions[.]” Id. at

41.

[9] On August 16, Defendants filed notice of removal of Bowman’s suit to the

Southern District of Indiana. In November, Defendants sued Bowman in the

same district court, for a third time alleging a copyright violation. As for

Bowman’s removed action, he stipulated he was not seeking damages greater

than $75,000, so the district court remanded the matter to the Hamilton

Superior Court on December 30 for lack of jurisdiction.

[10] On January 23, 2023, Defendants moved to dismiss Bowman’s remanded

lawsuit. Defendants’ motion to dismiss alleged (1) lack of personal jurisdiction

over Rawle, Montgomery McCracken, and Powell; and (2) failure to state a

claim for relief. 4 Defendants argued “merely filing and serving the

Pennsylvania [c]omplaint on Bowman” did not establish specific jurisdiction

over them in Indiana state court. Id. at 60. According to the motion, the

Center’s relationship with Rawle, Powell, or Montgomery McCracken “ha[d]

no bearing on whether personal jurisdiction” existed over them. Id. at 61. As

for the letter excerpted in Bowman’s complaint, the motion asserted Indiano

sent the communication and the letter alone was insufficient to establish

personal jurisdiction. Bowman filed a response opposing dismissal, and the

4

The Center did not challenge personal jurisdiction, but it did allege Bowman failed to state a claim for

relief.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 5 of 26

trial court held a hearing in May, after which the court took the matter under

advisement.

[11] In October 2024, the trial court held a case management conference. The court

had yet to rule on the motion to dismiss, but it set the matter for trial.

Defendants did not attend the conference. In November, the trial court issued a

case management order setting certain pretrial deadlines, including one for the

filing of Defendants’ answer. The deadline passed and Defendants did not file

an answer. On December 17, Bowman moved for default judgment after a

second deadline related to the statement of contentions and the witnesses list

passed without Defendants filing anything. Defendants submitted their

opposition to default judgment in early January 2025, and the trial court held a

hearing on the matter later that month, and again in March. In April, the court

issued an order staying the matter pending resolution of the Indiana federal

court copyright action. 5 About four months later, the Indiana federal court

granted summary judgment in Bowman’s favor in the copyright case, and

Bowman informed the Hamilton Superior Court of this development.

[12] In September 2025, the trial court entered default judgment against Defendants.

The court concluded in part:

1. On July 22, 2022, Plaintiff[] filed [his] Complaint.

5

On the same day, the court published an entry explaining it had intended to stay the matter as early as

February 2024. See id. at 161–62.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 6 of 26

2. On August 16, 2022[,] all Defendants appeared in this case

and filed a Notice of Filing Notice of Removal to Federal Court.

3. Exhibit A to the Notice of Removal stated:

6. Defendants each received a copy of the Complaint

and Summons in this action on July 25, 2022. Given the

service on Defendants on July 25, 2022, Defendants’

deadline to answer the Complaint was August 15, 2022[.]

4. By removing the case to Federal Court, Defendants’ deadline

to answer the Complaint was automatically extended by seven

days to August 22, 2022[,] pursuant to [Federal Rule of Civil

Procedure 81.]

5. Defendants did not answer the Complaint in federal court,

and hence, were in peril of default as of August 22, 2022. As of

this date, Defendants waived their defenses, including any that

might have been asserted in a Motion to Dismiss.

***

9. On January 23, 2023, Defendants filed in this Court a Motion

to Dismiss. This was five months after their August 22, 2022[,]

deadline to answer the Complaint.

10. On April 17, 2023, Plaintiff responded to Defendants’

Motion to Dismiss. That Motion remains pending.

11. On November 4, 2024, the Court entered a Case Management

Order stating in part:

The Court hereby sets the following deadlines.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 7 of 26

1) November 15, 2024—Defendants shall file

Answer(s) to Complaint.

2) December 13, 2024—Each party to file a

statement of contentions and its preliminary

witnesses and exhibits.

3) February 14, 2024—Discovery closes. 6

12. Defendants did not file an Answer to the Complaint by

November 15, 2024.

13. By December 13, 2024[,] Defendants did not file a Statement

of Contentions and preliminary witnesses and exhibits, even though

Plaintiff filed his.

14. On December 17, 2024, Plaintiff filed his Verified Motion for

Default Judgment in the amount of $75,000.

***

23. Here, default judgment is appropriate for the following

reasons:

a. Defendants did not file an Answer by either the August

24, 2022[,] deadline pursuant to Fed. Rule Civ. Pro 81(c)

or this Court’s Order to file an answer by November 15,

2024.

6

The reference to “2024” in the trial court’s order appears to be a mistake.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 8 of 26

b. Defendants did not file a Statement of Contentions and

preliminary witnesses and exhibits by their December 13,

2024[,] deadline. . . .

c. Defendants’ arguments opposing default judgment are

unpersuasive for the following reasons:

i. Defendants contend that the Court lacks personal

jurisdiction over them. This argument was waived

because it was not asserted as a defense before

Defendants’ deadline to file an answer, i.e., by

August 24, 2022[,] or November 15, 2024.

***

Accordingly, Plaintiff’s Motion for Default Judgment is

GRANTED[.]

Id. at 18–25.

[13] Defendants moved to correct error, and the trial court denied their motion.

Standards of Review

[14] We review a ruling on a motion to correct error for an abuse of discretion.

Bruder v. Seneca Mortg. Servs., LLC, 188 N.E.3d 469, 471 (Ind. 2022). A trial

court abuses its discretion when its ruling is clearly against the logic and effect

of the facts and circumstances before the court or if the court has misinterpreted

the law. Id. But where a decision turns on a question of law, we apply de novo

review. Dickerson v. Toney, 253 N.E.3d 1159, 1165 (Ind. Ct. App. 2025) (citing

Berg v. Berg, 170 N.E.3d 224, 227 (Ind. 2021)), trans. denied.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 9 of 26 [15] Under Indiana Trial Rule 55(A), a trial court is authorized to enter default

judgment if a defendant fails to respond to the plaintiff’s complaint. Expert Pool

Builders, LLC v. Vangundy, 224 N.E.3d 309, 314 (Ind. 2024). A default

judgment is an extreme remedy, reserved for parties who fail to defend or

prosecute a suit. Id. at 314–15. This Court reviews a trial court’s decision to

enter a default judgment for an abuse of discretion. Id. at 312. Indiana law

prefers disposition of cases on their merits, so a trial court should exercise its

discretion in light of the disfavor in which default judgments are held. Coslett v.

Weddle Bros. Constr. Co., 798 N.E.2d 859, 861 (Ind. 2003). In other words, “the

trial court must balance the need for an efficient judicial system with the

judicial preference for deciding disputes on the merits.” Kmart Corp. v.

Englebright, 719 N.E.2d 1249, 1253 (Ind. Ct. App. 1999), trans. denied. “Any

doubt of the propriety of a default judgment should be resolved in favor of the

defaulted party.” Riddle v. Cress, 153 N.E.3d 1112, 1113 (Ind. 2020).

The trial court abused its discretion in granting default

judgment.

[16] In this case, the trial court granted Bowman’s motion for default judgment

without addressing the merits of Defendants’ motion to dismiss. The court

determined Defendants waived available defenses, including a challenge to

personal jurisdiction, “because it was not asserted as a defense” before the

deadline “to file an answer[.]” Appellants’ App. Vol. 2 at 24. For the reasons

explained below, we conclude otherwise.

[17] Indiana trial rules permit certain defenses to be asserted by motion as follows:

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 10 of 26

(A) When Presented. The time allowed for the presentation of

defenses and objections in a motion or responsive pleading shall

be computed pursuant to the provisions of Rule 6(C).

(B) How Presented. Every defense, in law or fact, to a claim for

relief in any pleading, whether a claim, counterclaim, crossclaim, or third-party claim, shall be asserted in the responsive

pleading thereto if one is required; except that at the option of the

pleader, the following defenses may be made by motion:

***

(2) Lack of jurisdiction over the person,

***

(6) Failure to state a claim upon which relief can be granted,

which shall include failure to name the real party in interest

under Rule 17;

***

A motion making any of these defenses shall be made before

pleading if a further pleading is permitted or within twenty [20]

days after service of the prior pleading if none is required. If a

pleading sets forth a claim for relief to which the adverse party is

not required to serve a responsive pleading, any of the defenses in

section (B)(2), (3), (4), (5) or (8) is waived to the extent

constitutionally permissible unless made in a motion within

twenty [20] days after service of the prior pleading. No defense

or objection is waived by being joined with one or more other

defenses or objections in a responsive pleading or motion.

***

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 11 of 26

(G) Consolidation of Defenses in Motion. A party who makes

a motion under this rule may join with it any other motions

herein provided for and then available to him. If a party makes a

motion under this rule but omits therefrom any defense or

objection then available to him which this rule permits to be

raised by motion, he shall not thereafter make a motion based on

the defense or objection so omitted. He may, however, make

such motions as are allowed under subdivision (H)(2) of this rule.

(H) Waiver or Preservation of Certain Defenses.

(1) A defense of lack of personal jurisdiction over the person,

improper venue, insufficiency of process, insufficiency of service

of process, or the same action pending in another state court of

this state is waived to the extent constitutionally permissible:

(a) if omitted from a motion in the circumstances

described in subdivision (G),

(b) if it is neither made by motion under this rule nor

included in a responsive pleading or an amendment

thereof permitted by Rule 15(A) to be made as a matter of

course.

(2) A defense of failure to state a claim upon which relief can be

granted, a defense of failure to join an indispensable party under

Rule 19(B), and an objection of failure to state a legal defense to

a claim may be made in any pleading permitted or ordered under

Rule 7(A) or by motion for judgment on the pleadings, or at the

trial on the merits.

Ind. Trial Rule 12 (2007).

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 12 of 26 [18] In relevant part, Indiana trial rules also provide the applicable deadline for

service of a responsive pleading following service of a Rule 12 motion:

(C) Service of Pleadings and Rule 12 Motions. A responsive

pleading required under these rules, shall be served within twenty

[20] days after service of the prior pleading. Unless the court

specifies otherwise, a reply shall be served within twenty [20]

days after entry of an order requiring it. The service of a motion

permitted under Rule 12 alters the time for service of responsive

pleadings as follows, unless a different time is fixed by the court:

(1) if the court does not grant the motion, the responsive pleading

shall be served in ten [10] days after notice of the court’s action;

(2) if the court grants the motion and the corrective action is

allowed to be taken, it shall be taken within ten [10] days, and the

responsive pleading shall be served within ten [10] days

thereafter.

T.R. 6 (2013).

[19] In Morton-Finney v. Gilbert, a panel of this Court considered whether a

defendant’s failure to file an answer entitled the plaintiff to default judgment.

646 N.E.2d 1387, 1388 (Ind. Ct. App. 1995), trans. denied. Morton-Finney was

employed by the Indianapolis Public Schools as an instructional program

facilitator, and she filed a petition for a temporary restraining order against the

defendant superintendent to prevent her reassignment to a less desirable

position. Id. Without filing an answer, the superintendent moved to dismiss

Morton-Finney’s petition for failure to state a claim under Rule 12(B)(6). Id.

Morton-Finney moved for default judgment. Id. The trial court denied default

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 13 of 26

judgment and granted the superintendent’s motion to dismiss. Id. On appeal,

Morton-Finney contended she was entitled to default because the

superintendent did not file an answer. Id. The reviewing panel disagreed,

concluding the superintendent had filed a timely response. Id. According to the

court, “A motion to dismiss for failure to state a claim upon which relief can be

granted is a proper responsive motion.” Id.

[20] Along similar lines, in Sportsman’s Paradise, Inc. v. Sports Center, Inc., a panel of

this Court was faced with deciding if an untimely answer was sufficient to avoid

default judgment. 424 N.E.2d 1073, 1075 (Ind. Ct. App. 1981). The

defendants’ counsel in Sportsman’s Paradise entered an appearance and

attempted to file answers and counterclaims, which the trial court struck as

untimely pursuant to Trial Rule 6. Id. at 1074–75. The plaintiff moved for

default judgment. After a hearing, the court granted default judgment in the

plaintiff’s favor. The panel concluded the trial court erred, explaining, “The

crucial time for determining whether a party has in fact failed to plead is at the

time the motion for default is filed.” Id. at 1075. Sportsman’s Paradise

interpreted Rule 55(A) to indicate an answer is sufficient to avoid default, even

if the answer is filed late under Rule 6. See id. That’s because, as the Court

explained, one of the “primary objectives” of Rule 55 is to “allow for the

enforcement of a timely litigation process for the purpose of avoiding

procedural delay.” Id. Where the defendants had filed an answer before the

plaintiff moved for default judgment, the Court reasoned, it was “virtually

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 14 of 26

impossible for the moving party to establish” the defendants failed to plead in

contravention of Rule 55. Id.

[21] Here, Bowman filed his complaint in state court on July 22, 2022. Defendants

received service of the complaint and summons on July 25. Defendants’

counsel entered an appearance on August 16 and on the same day they filed a

notice of removal to the Southern District of Indiana. Defendants did not file

an answer before removal. The district court remanded the matter to the state

court on December 30. On January 23, 2023, Defendants filed their motion to

dismiss, challenging personal jurisdiction and alleging failure to state a claim

upon which relief can be granted. See T.R. 12(B)(2), (6). Bowman filed a

response opposing dismissal, and the trial court held a hearing on the motion in

May. The court then took the matter under advisement—and so it remained

until the grant of default judgment in 2025.

[22] In the order granting default judgment, the trial court found Defendants waived

available defenses as early as August 15, 2022—which was twenty days

following receipt of service. Strictly speaking, Defendants’ motion to dismiss

was filed after the twenty-day deadline set in Trial Rule 6(C). But we must also

look at the time the motion for default judgment is filed to determine whether a

party has failed to plead. See Sportsman’s Paradise, 424 N.E.2d at 1075. Trial

Rule 12 permitted Defendants to assert and consolidate defenses in a responsive

motion, which is precisely what they did. See T.R. 12(B), (G). By the time

Bowman moved for default in late 2024, Defendants’ responsive motion

challenging personal jurisdiction and alleging failure to state a claim was

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 15 of 26

squarely before the trial court. See Morton-Finney, 646 N.E.2d at 1388. At that

point, the motion to dismiss—still under the court’s advisement—was sufficient

to avoid default judgment. See Sportsman’s Paradise, 424 N.E.2d at 1075.

[23] Relatedly, the trial court found Defendants “were in peril of default as of

August 22, 2022[,]” which is the date the court determined Defendants’ answer

was due in federal court following notice of removal. Appellants’ App. Vol. 2 at

19 (citing Fed. R. Civ. P. 81(c)(2)(C)). Bowman reprises the trial court’s

reasoning in his appellate brief, arguing Defendants waived all available

defenses because they did not file a response in federal court. See Appellee’s Br.

at 16–17.

[24] For cases removed to federal court, the Federal Rules of Civil Procedure

(“FRCP”) state:

(1) Applicability. These rules apply to a civil action after it is

removed from a state court.

(2) Further Pleading. After removal, repleading is unnecessary

unless the court orders it. A defendant who did not answer

before removal must answer or present other defenses or

objections under these rules within the longest of these periods:

(A) 21 days after receiving—through service or

otherwise—a copy of the initial pleading stating the claim

for relief;

(B) 21 days after being served with the summons for an

initial pleading on file at the time of service; or

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 16 of 26

(C) 7 days after the notice of removal is filed.

Fed. R. Civ. P. 81(c) (2009).

[25] “Generally, the removal of a case to federal court divests the state court of

jurisdiction.” Noons v. First Merchs. Bank, 268 N.E.3d 1250, 1253 (Ind. Ct. App.

2025). “An order remanding an action to federal court suspends or holds the

state court jurisdiction in abeyance either until the action is terminated in

federal court or until the action is remanded to the state court.” Id.; see also Tom

James Co. v. Zurich Am. Ins. Co., 221 N.E.3d 1261, 1267 n.5 (Ind. Ct. App. 2023)

(indicating after removal to federal court became effective, all proceedings in

state court had ceased), trans. denied.

[26] Whether Defendants waived the right to move to dismiss is distinct from the

question of whether Defendants waived the right to challenge personal

jurisdiction altogether. See Touro Coll. v. Fondazione Touro Univ. Rome Onlus, No.

16 Civ. 3136 (DAB), 2017 WL 4082481, at *5 (S.D.N.Y. Aug. 31, 2017)

(“[T]he question related to Rule 81(c)(2) is whether [d]efendants waived the

right to bring a Motion to Dismiss, not whether they waived their personal

jurisdiction objection itself”). In the context of a non-removed case, the Court

of Appeals for the Seventh Circuit interpreted the federal equivalent to Rule 12

to permit a litigant to challenge personal jurisdiction either in a responsive

pleading filed within the applicable deadline under FRCP 12(a), “or in a

motion with no similar time limit specified.” Hedeen Int’l, LLC v. Zing Toys, Inc.,

811 F.3d 904, 906 (7th Cir. 2016); see also Pierson v. Nat’l Inst. for Lab. Rels. Rsch.,

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 17 of 26

No. 15 C 11049, 2016 WL 6093490, at *5 (N.D. Ill. Oct. 17, 2016) (applying

the holding in Hedeen Int’l in removed case).

[27] Against this backdrop, we are not persuaded Defendants waived all 12(B)

defenses while the case was in federal court. In any event, Bowman never

moved for default judgment in federal court; rather, he stipulated his damages

were no greater than $75,000, thereby depriving the federal court of jurisdiction

and resulting in remand to Indiana state court. See 28 U.S.C. § 1332(a) (2012).

And while the case was removed, jurisdiction of the state court was suspended

until remand. Noons, 268 N.E.3d at 1253. In short, FRCP 81 does not control

the outcome here.

[28] Independent of the waiver analysis, the trial court found Bowman entitled to

default judgment as a sanction for Defendants’ failure to comply with court

discovery orders. See Appellants’ App. Vol. 2 at 23 (citing T.R. 37(B)(2)(c)). Trial

Rule 37(B)(2)(c) permits trial courts to sanction a party who “fails to obey an

order to provide or permit discovery” by, among other things, rendering default

“against the disobedient party.” On this alternative basis, the court granted

default judgment partly because Defendants did not file an answer on

November 15, 2024. See Appellants’ App. Vol. 2 at 147 (case management order).

First, as Defendants argue, Rule 37 is inapplicable because the timely filing of

an answer “is not a situation involving discovery violations[.]” Appellants’ Br. at

36; see also Wright v. Miller, 989 N.E.2d 324, 327 (Ind. 2013) (observing Rule 37

gives trial courts discretion to impose sanctions to ensure cooperative

discovery). Second, with the motion to dismiss under advisement since May

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 18 of 26

2023, no answer was due until the court ruled on the pending motion. See T.R.

6(C). Given our preference for deciding disputes on their merits and avoiding

procedural delay, Sportsman’s Paradise, 424 N.E.2d at 1075, we conclude the

trial court abused its discretion by granting default. See Bruder, 188 N.E.3d at

471. Where, as here, a party’s responsive motion remains pending and before

the trial court when a party moves for default judgment, the court has an

obligation to address the motion to dismiss before deciding to grant default.

There is no specific jurisdiction in Indiana.

[29] Rawle, Montgomery McCracken, and Powell challenge the trial court’s

personal jurisdiction over them. Defendants contend the court’s grant of

default judgment in Bowman’s favor is void in the absence of personal

jurisdiction. See Appellants’ Br. at 39 (citing Stidham v. Whelchel, 698 N.E.2d

1152, 1154–55 (Ind. 1998)). We agree.

[30] Personal jurisdiction refers to a trial court’s power to impose a judgment on a

particular defendant. Boyer v. Smith, 42 N.E.3d 505, 509 (Ind. 2015). “We

analyze whether personal jurisdiction exists in Indiana under the Due Process

Clause of the Fourteenth Amendment to the United States Constitution.” State

v. TikTok Inc., 245 N.E.3d 681, 688 (Ind. Ct. App. 2024), trans. denied; see also

T.R. 4.4(A) (listing acts serving as a basis for jurisdiction and stating, “a court

of this state may exercise jurisdiction on any basis not inconsistent with the

Constitutions of this state or the United States”). Before an Indiana court can

assert personal jurisdiction over a defendant, the Due Process Clause of the

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 19 of 26

Fourteenth Amendment requires the defendant to have “minimum contacts”

with the state, so the maintenance of the suit does not offend traditional notions

of fair play and substantial justice. Boyer, 42 N.E.3d at 509. A minimum

contacts analysis for personal jurisdiction involves two separate concepts:

general jurisdiction and specific jurisdiction. Tom James, 221 N.E.3d at 1269.

No party argues general jurisdiction is applicable in this case.

[31] As the Indiana Supreme Court explained:

Specific jurisdiction requires that the defendant purposefully

availed itself of the privilege of conducting activities within the

forum state so that the defendant reasonably anticipates being

haled into court there. A single contact with the forum state may

be sufficient to establish personal specific jurisdiction over a

defendant, if it creates a substantial connection with the forum

state and the suit is related to that connection. But a defendant

cannot be haled into a jurisdiction solely as a result of random,

fortuitous, or attenuated contacts or of the unilateral activity of

another party or a third person.

LinkAmerica Corp. v. Cox, 857 N.E.2d 961, 967 (Ind. 2006) (internal quotation

marks and citations omitted). If the defendant has contacts with the forum state

sufficient to establish specific jurisdiction, due process mandates the assertion of

personal jurisdiction over the defendant is reasonable. Id.

[32] Personal jurisdiction is a question of law we review de novo. Tom James, 221

N.E.3d at 1266 (citing Boyer, 42 N.E.3d at 508). “[W]hether personal

jurisdiction exists can depend upon factual determinations concerning a

defendant’s contacts with the forum state—in which case the challenger bears

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 20 of 26

the burden of disproving personal jurisdiction.” Boyer, 42 N.E.3d at 508. If the

trial court issues findings of jurisdictional facts, those findings are reviewed for

clear error. Tom James, 221 N.E.3d at 1266. “Where the trial court did not find

jurisdictional facts, we may accept the plaintiff’s well-pleaded facts to the extent

they are not challenged, and we may view challenged facts in favor of the

plaintiff.” Davis v. Simon, 963 N.E.2d 46, 51 (Ind. Ct. App. 2012) (citation

omitted), trans. dismissed. A default judgment without minimum contacts

violates due process and is void. Stidham, 698 N.E.2d at 1154.

[33] In the present case, the trial court did not make jurisdictional findings.

Bowman is a resident of Indiana. Rawle is president of the Center and resides

in Maine. Powell is a licensed attorney in Pennsylvania. Montgomery

McCracken is a Pennsylvania law firm organized under the laws of that

jurisdiction. The Center is incorporated in New York with its headquarters in

Maine. Only Rawle, Powell, and Montgomery McCracken challenge personal

jurisdiction.

[34] In his complaint, Bowman alleged Defendants sued him in Pennsylvania

federal court for the sole purpose of extorting money from him. Bowman

claimed Rawle and the Center gathered “highly intrusive personal information”

about his net worth and—armed with this information—hired an Indiana

attorney who sent him a demand letter in pursuit of their “utterly frivolous”

claims in Pennsylvania. Appellants’ App. Vol. 2 at 31. Bowman accordingly

claimed the “conspiring Defendants [were] equally liable for the other’s

wrongful actions” in the State of Indiana. Id. at 41.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 21 of 26 [35] In Boyer, the Indiana Supreme Court reviewed a challenge to personal

jurisdiction in a case similarly alleging damages based in tort. 42 N.E.3d at

507–08. The plaintiffs in Boyer were residents of Indiana who sued a Kentucky

attorney over her representation of a client (the plaintiffs’ former employee) in

an employment discrimination suit. Id. After examining the defendant’s

contacts in Indiana, the Court affirmed the trial court’s decision finding a lack

of personal jurisdiction over the attorney. Id. at 512. The Court emphasized

that a defendant’s relationship to plaintiffs or third parties, without more, did

not create a sufficient basis for jurisdiction. Id. at 511–12 (citing Walden v. Fiore,

571 U.S. 277, 286 (2014)). Central to the Court’s analysis was the absence of

Indiana-directed conduct: the defendant was not licensed in Indiana, had never

practiced here, and otherwise had no contacts with this state aside from those

necessary to represent her former client. Boyer, 42 N.E.3d at 511–12. In sum,

as the defendant’s connection to Indiana resulted from the actions of others, the

attorney herself “neither created nor invoked sufficient minimum contacts

within Indiana to warrant specific personal jurisdiction[.]” Id. at 512.

[36] This Court had occasion to consider an analogous question in Richards & O’Neil,

LLP v. Conk, where the plaintiff brought suit in Indiana state court against the

New York law firm Richards & O’Neil, LLP and one of its attorneys. 774

N.E.2d 540, 543 (Ind. Ct. App. 2002). The dispute arose from the sale of a

privately-owned company headquartered in Indianapolis, Day Dream, Inc., to

Cullman Ventures, Inc., a New York corporation. Id. Following the sale of

Day Dream, there was a dispute between its shareholders and Cullman, and the

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 22 of 26

parties engaged in arbitration in New York. Id. at 544. Pursuant to the

arbitration, Richards & O’Neil attorneys appeared pro hac vice in Indiana courts

on behalf of Cullman and Day Dream, and some of its lawyers traveled to

Indiana to conduct document review. Id. at 545. The New York arbitration

settled as to all shareholders, except Edward Conk. Id.

[37] Conk subsequently sued Richards & O’Neil in Indiana on several theories,

including breach of contract and professional negligence. Id. Conk also sued

one of the partners at the firm because the attorney signed a legal opinion letter

distributed to shareholders which allegedly contained misleading information

upon which Conk relied. Id. at 544, 546. The defendants filed a motion to

dismiss, in which they raised a personal jurisdiction challenge. Id. at 545. The

trial court denied the motion. Id.

[38] On appeal, this Court reversed. The panel concluded Richards & O’Neil and

the attorney did not have sufficient contacts in Indiana to warrant jurisdiction.

Id. at 546. In explaining its holding, the court emphasized Richards & O’Neil

was a New York partnership, did not have an office in Indiana, and did not

advertise or solicit business in the state. Id. Regarding the attorney-defendant,

the court held his contacts within Indiana were too attenuated as he had never

traveled here on business and whatever contacts he had arose from the actions

of his client. See id. at 546–47.

[39] In this matter, Montgomery McCracken is a Pennsylvania partnership the

Center hired to prosecute the second action in Pennsylvania federal court. Like

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 23 of 26

the firm in Conk, Montgomery McCracken has no offices in Indiana and does

not advertise or solicit business in this state. There is no indication

Montgomery McCracken attorneys regularly practice or conduct business in

Indiana courts. Powell is not licensed to practice in Indiana and there is no

evidence he practiced here before this lawsuit. He has no contacts within

Indiana aside from those necessary to represent his client. See Boyer, 42 N.E.3d

at 511–12; Conk, 774 N.E.2d at 546–47. Importantly, Bowman’s complaint

alleged the Center and its lawyers conspired to pursue frivolous claims against

him in Pennsylvania, not Indiana. In addition, it was attorney Indiano who

drafted the supposedly threatening letter Bowman quoted in his complaint,

which he received before the Center had retained either Montgomery

McCracken or Powell. See Tr. Vol. 2 at 15. Indiano’s letter alone does not

create a sufficient basis for jurisdiction. See Boyer, 42 N.E.3d at 511. We

conclude there are not sufficient contacts within Indiana to justify subjecting

Montgomery McCracken or Powell to jurisdiction in this state.

[40] The outcome is no different for Rawle. Bowman alleged Rawle caused service

of process to issue against him in Indiana despite knowing the Center’s

Pennsylvania actions lacked merit. He also alleged Rawle, the Center, or their

counsel gathered information about his Indiana residence to extort money and

were responsible for the demand letter Indiano drafted. See Appellants’ App. Vol.

2 at 28–29. “But the plaintiff cannot be the only link between the defendant and

the forum. Rather, it is the defendant’s conduct that must form the necessary

connection with the forum State that is the basis for its jurisdiction over” her.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 24 of 26

Walden, 571 U.S. at 285–86. The fact Bowman received service of process in

Indiana and a demand letter, standing alone, does not show Rawle created

contacts within or a substantial connection to Indiana warranting jurisdiction.

See Boyer, 42 N.E.3d at 512; see also Walden, 571 U.S. at 285–86.

[41] In short, neither Rawle, Montgomery McCracken, nor Powell invoked

sufficient minimum contacts within Indiana to support specific jurisdiction over

them. The trial court cannot exercise jurisdiction over these defendants in a

manner consistent with due process. See Stidham, 698 N.E.2d at 1154. As a

result, the court’s grant of default judgment is void, and Bowman’s claims

against Rawle, Montgomery McCracken, and Powell must be dismissed. See

id. 7

Conclusion

[42] The trial court’s grant of default judgment is reversed as to all Defendants. We

remand with instructions to dismiss Bowman’s claims against Rawle,

Montgomery McCracken, and Powell as the court lacks jurisdiction over them.

Because the Center does not challenge personal jurisdiction, we remand the

claim against it for further proceedings consistent with this opinion, including

7

The personal jurisdiction analysis is not complete just because sufficient minimum contacts are found.

Where a defendant has contacts with the forum state sufficient for specific personal jurisdiction, we must still

determine whether the assertion of personal jurisdiction over the defendant is reasonable. TikTok, 245

N.E.3d at 691. However, because we conclude Rawle, Montgomery McCracken, and Powell did not have

sufficient contacts within Indiana, we need not reach the reasonableness inquiry. These three defendants

additionally argue Bowman’s complaint against them failed to state a proper claim. As we determine

Indiana courts do not have jurisdiction over them here, we will not address those arguments.

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 25 of 26

the trial court’s consideration of the Center’s pending 12(B)(6) motion to

dismiss.

[43] Reversed and remanded.

Bradford, J., and Pyle, J., concur.

ATTORNEY FOR APPELLANTS

Charles R. Whybrew

Lewis Wagner & Trimble

Indianapolis, Indiana

ATTORNEY FOR APPELLEE

Paul B. Overhauser

Overhauser Law Offices LLC

Greenfield, Indiana

Court of Appeals of Indiana Opinion 25A-PL-2715 August 31, 2026 Page 26 of 26