Massa, J.
After being denied Medicaid reimbursement for over-the-counter medicines prescribed to its patients, ResCare Health Services, Inc. unsuccessfully sought administrative and judicial review, including a request for declaratory judgment. But the trial court concluded the request was insufficiently pleaded and ResCare’s patients needed to be added to the litigation. Without determining whether the issue was sufficiently pleaded, the Court of Appeals affirmed, agreeing that the patients needed to be added before a declaratory judgment could be issued.
While we summarily affirm the disposition of ResCare’s other arguments, we disagree that its declaratory judgment request should not be considered on the merits. Under Indiana’s notice pleading standards, ResCare sufficiently pleaded its declaratory judgment request. And its patients need not be sued for ResCare to seek declaratory relief blocking a government enforcement action. We reverse and remand for the trial court to consider the declaratory judgment request on the merits.
….
While we summarily affirm the Court of Appeals on the first two issues, see Ind. Appellate Rule 58(A)(2), we write to address the declaratory judgment issue. As its alternative argument, ResCare requested a declaratory judgment stating that it could charge patient accounts for the costs of the over-the-counter drugs that fell outside Medicaid. Despite the trial court acknowledging that ResCare “request[ed]” this declaratory judgment, it declined to issue one because ResCare did not file a separate complaint, the declaratory judgment claim was not sufficiently pleaded, and the patients should have been joined to the litigation. Appellant’s App. Vol. II, p.12. We first address whether ResCare needed to file a separate complaint for a declaratory judgment, and, if not, then whether it sufficiently pleaded its declaratory judgment claim. Because we ultimately conclude ResCare did not need to file a separate complaint and it sufficiently pleaded its declaratory judgment claim, we then turn to whether ResCare’s patients need to be joined. We conclude they do not, so we reverse and remand.
I. ResCare did not need to file a separate complaint for a declaratory judgment.
The trial court denied ResCare’s declaratory judgment request, in part, because ResCare did not file a separate complaint for a declaratory judgment. The FSSA argued the trial court’s review in a “judicial action is limited to a review of the administrative proceedings,” and the trial court does not have the authority to issue relief, like a declaratory judgment, that “the agency was not authorized to issue.” Appellant’s App. Vol. III, pp. 231–32. Under that argument, ResCare could never obtain a declaratory judgment without filing a separate complaint, which would likely be consolidated with its judicial review petition. While the FSSA is correct that it cannot issue a declaratory judgment, it is incorrect that the trial court cannot. See I.C. § 34-14-1-1. The suggestion that ResCare needed to file a separate complaint is flawed, and in direct opposition to our judicial system’s principles of judicial economy and the avoidance of multiple lawsuits where possible.
Indiana generally disfavors multiple lawsuits involving similar issues….
While a party typically can only obtain judicial review of issues raised before an agency, ResCare was not seeking judicial review of this issue—it was seeking a declaratory judgment. A petition for review is analogous to a complaint and allows a party to include other claims that were previously unavailable on administrative review. See Ind. Dep’t of Highways v. Dixon, 541 N.E.2d 877, 880 (Ind. 1989); Midwest Ent. Ventures, Inc. v. Town of Clarksville, 158 N.E.3d 787, 792 (Ind. Ct. App. 2020), trans. denied. Nothing in the Administrative Orders and Procedures Act suggests parties seeking judicial review are barred from adding additional claims that were previously unavailable on administrative review. See I.C. § 4-21.5-5-1; T.R. 18(A). While ResCare could have filed this declaratory judgment request as a separate action, it did not have to do so. To hold otherwise would needlessly incentivize numerous lawsuits on related issues.
II. Under Indiana’s notice pleading requirements, ResCare sufficiently pleaded its declaratory judgment claim.
….
…ResCare has expressly requested a declaratory judgment at every stage of these proceedings. During the administrative proceedings, ResCare requested this declaratory judgment from the ALJ, who declined to rule on the issue. [Footnote: As previously explained, the FSSA does not have any authority to issue the requested declaratory judgment. So, while nothing prohibits a party from requesting it before an agency, not requesting it before the agency does not waive the claim for judicial review. We include these requests and arguments from the administrative proceedings only to show the FSSA’s notice of ResCare’s intent to seek a declaratory judgment. But even if ResCare had not raised the declaratory judgment issue during administrative review, it still could have raised it for the first time in its petition for judicial review.] ResCare appealed the ALJ’s decision to the final agency authority, and the FSSA concluded it could not rule on the issue because it was not ripe and issuing a declaratory judgment “was beyond the authority of the ALJ and agency review.” Appellant’s App. Vol. II, pp. 22–23. In response to ResCare’s objections to the ALJ’s order, the FSSA argued this issue was “more akin to a declaratory judgment request, which is well beyond the purview of this administrative forum.” Id., p.92. Then in ResCare’s petition for judicial review, it stated one of the two issues raised during administrative review was “whether ResCare could charge the unreimbursed costs for such drugs to the personal funds account of the client.” Id., p.17. ResCare argued the FSSA erred in concluding the issue was not ripe, and to the extent the agency’s order rested on the concern that it “could not issue a declaratory judgment regarding the reimbursement from personal funds accounts, this Court does have the authority to do so.” Id. at 18–20 (citing I.C. § 34-14-1-1; T.R. 57).
….
While explicitly referencing the declaratory judgment in ResCare’s prayer for relief may have been “highly desirable,” it was not necessary under our notice pleading standards. Rankin, 260 Ind. at 606, 294 N.E.2d at 606. All that was required was pleading the operative facts necessary to set forth an actionable claim, which ResCare did, in addition to its express requests for a declaratory judgment and legal arguments about why it deserved one. Trail, 845 N.E.2d at 135. This express request is evinced by the trial court itself referencing ResCare’s “request[]” for the declaratory judgment. Appellant’s App. Vol. II, p.12. Indeed, ResCare pleaded its declaratory judgment request far more expressly and thoroughly than the plaintiff in Myers, who still sufficiently pleaded a declaratory judgment request because he “sufficiently stated facts that would support a declaratory judgment action.” 968 N.E.2d at 303. Compared to the pleadings in Myers, and under our notice pleading standards, we have no trouble concluding the FSSA was sufficiently notified of ResCare’s request for a declaratory judgment. At every level of these proceedings, ResCare argued for and requested the declaratory judgment, and the FSSA has argued against it. Like the defendants in Meyers, the adequacy of the notice was shown by the defendants’ pleadings. Id. Here, the FSSA consistently refuted the issue in its responsive pleadings, proving it was on notice.
Notice pleading developed “as a reaction to the archaic and overly technical pleading standards of the common law” and code pleading regimes. James V. Bilek, Twombly, Iqbal, and Rule 8(C): Assessing the Proper Standard to Apply to Affirmative Defenses, 15 Chap. L. Rev. 377, 379 n.20 (2011). Indeed, our notice pleading system mandates that all pleadings be “construed as to do substantial justice, lead to disposition on the merits, and avoid litigation of procedural points.” T.R. 8(F). And “whenever possible, ‘we prefer to resolve cases on the merits instead of on procedural grounds.’” Pierce v. State, 29 N.E.3d 1258, 1267 (Ind. 2015) (quoting Roberts v. Cmty. Hosps. of Ind., Inc., 897 N.E.2d 458, 469 (Ind. 2008)). The trial court’s denial on these technical grounds is what our notice pleading system seeks to avoid. The FSSA has long been informed of the declaratory judgment issue, which satisfies our notice pleading system.
III. ResCare’s patients do not have to be joined to the litigation before ResCare’s declaratory judgment request can be considered.
….
However, joinder is not required when a party is tangential to the dispute. Our decision in Ball State University v. Irons is illustrative; there, a woman sought to join Ball State University as a necessary party in a dispute with her former husband over college expenses for their daughter. 27 N.E.3d at 722. But Ball State was not necessary to resolve the amount of unpaid fees owed to it, nor was it necessary to determine future education expenses, especially considering the daughter had already transferred universities. Id. Here, the patients’ joinder is not necessary to determine whether ResCare violates Medicaid regulations by directly charging the patients for non-covered, over-the-counter medicines. ResCare’s concern is with the FSSA, and it “only seeks protection from a later enforcement action by the FSSA.” Pet. to Trans. at 19. Requiring ResCare to sue its patients before it can obtain “relief from uncertainty and insecurity” about the legality of its proposed solutions is inapposite to the purpose of declaratory judgments. Watson, 181 Ind App. at 159, 390 N.E.2d at 1085. Adding ResCare’s patients, who are individuals of limited means with intellectual disabilities, to the litigation when they have no legally cognizable interest at issue, nor any role in a potential enforcement action by the FSSA for Medicaid violations, is neither “just” nor “economical.” Id. at 160, 390 N.E.2d at 1085. We conclude the FSSA did not carry its burden to prove joinder was required, and the trial court abused its discretion in declining to issue the declaratory judgment on this basis. [Footnote omitted.]
Conclusion
While we summarily affirm the Court of Appeals on the statutory interpretation and takings issues, we reverse and remand for the trial court to consider ResCare’s declaratory judgment request on the merits.
Rush, C.J., and Slaughter and Goff, JJ., concur. David, J., concurs in result.