Rush, C.J.
Across Indiana, judges, clerks, court reporters, bailiffs, and others are working to resolve over 1.5 million pending cases. In 2023, our trial courts disposed of over 1 million cases. Respect for the finality of judgments is thus crucial to the efficient functioning of our legal system. Finality conserves limited resources, provides certainty and stability, and protects the interests of parties by enabling closure and reducing prolonged litigation. While our trial rules recognize the importance of finality, they also provide litigants with tools to set aside a final judgment in limited circumstances. But courts must enforce the procedural and substantive requirements that cabin those tools.
Here, the trial court entered summary judgment against a defendant for an unpaid business debt. Within thirty days of that decision, someone else admitted in an unsworn letter to fraudulently signing the loan in the defendant’s name. But the defendant did not file a motion to correct error or perfect an appeal. Nevertheless, on the defendant’s motion several months later, the court set aside its judgment based on fraud under Trial Rule 60(B)(3). Applying our trial rules and well-settled case law, we hold that the trial court abused its discretion in granting this relief. The trial court could not use Trial Rule 60(B)(3) to grant relief on grounds that the defendant could have raised in a motion to correct error. And there is no evidence that the alleged fraud prejudiced the defendant’s presentation of her case. We therefore reverse.
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Here, AFC asserts that the trial court abused its discretion in granting Liu relief under Trial Rule 60(B)(3), arguing that Liu could have raised Ao’s alleged fraud by designating evidence in response to AFC’s motion for summary judgment or by moving to correct error after judgment was entered. Liu concedes that the evidence she presented in her Rule 60(B)(3) motion “had already been presented” to the trial court through the unsworn letters before AFC obtained summary judgment, but she contends that the court did not abuse its discretion in granting her relief.
We agree with AFC. In reaching that decision, we first outline how a litigant, such as Liu, can oppose summary judgment and seek relief in the trial court from a final summary judgment decision. We then explain why the court here misinterpreted the law in granting Liu relief under Trial Rule 60(B)(3).
I. The trial court could not grant Liu relief from final judgment on the basis of fraud.
To explain why the trial court misinterpreted the law in granting relief to Liu based on fraud, we first set out how a party may oppose summary judgment and how they can challenge a judgment in the trial court once it becomes final. After clarifying the relevant trial rules and caselaw, we then apply them to this case. We ultimately conclude that the trial court improperly granted relief under Trial Rule 60(B)(3) as a substitute for a timely motion to correct error and a subsequent appeal. And we find Liu failed to show that Ao’s alleged fraud prejudiced her ability to present her case.
A. Parties challenging final judgments based on fraud must comply with procedural and substantive requirements.
Our trial rules require that parties receive a fair hearing before judgment, including summary judgment. The rules also lay out procedures for challenging final judgments. But these same rules cabin opportunities for relitigation in the interest of finality. As we explain below, a party can designate evidence at the summary judgment stage until the deadline expires. And once a judgment becomes final, they can timely show that an adverse party’s fraud prejudiced the presentation of their case. But a trial court cannot grant relief without enforcing these requirements. Making exceptions would lead to disparate treatment of litigants and, by improperly permitting relitigation of issues already determined, undermine finality.
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Once a trial court enters final summary judgment, Trial Rules 59 and 60(B) come into play. Trial Rule 59 gives a party thirty days—from when the court notes the judgment in the Chronological Case Summary—to file a motion to correct error. T.R. 59(C). That motion can raise a broad range of challenges, including newly discovered evidence. See Weida v. Kegarise, 849 N.E.2d 1147, 1150 (Ind. 2006) (noting that the trial rules do not list all the bases for a motion to correct error); T.R. 59(A)(1). Trial Rule 60(B) also enables a party to seek relief from summary judgment. But this rule “is meant to afford relief from circumstances which could not have been discovered during the period a motion to correct error could have been filed.” Bello, 102 N.E.3d at 894. And thus, Rule 60(B) cannot be used as a substitute for a timely motion to correct error and a subsequent appeal. See id.
Relief under Trial Rule 60(B) is limited to enumerated grounds and applicable time limits. One such ground, which is relevant here, is for “fraud . . . of an adverse party.” T.R. 60(B)(3).1 Under this “limited exception to the general rule of finality of judgments,” a party must show that fraud prevented them from “fully and fairly presenting” their case. Outback Steakhouse, 856 N.E.2d at 73–74. They must also demonstrate “a meritorious claim or defense” to ensure that granting relief would not be “an empty exercise.” Id. at 73 (quotations omitted). And they must make these showings “not more than one year” after the judgment was entered. T.R. 60(B).
When a party seeking relief cannot meet Trial Rule 60(B)(3)’s requirements—such as when “the fraud is not chargeable to an adverse party”—they have two other ways to attack the judgment based on fraud. Stonger, 776 N.E.2d at 356–57. The first, recognized under Trial Rule 60(B)’s savings clause, is through an independent action requesting a trial court to “relieve a party from a judgment, order or proceeding.” T.R. 60(B). But this “remedy is extremely limited” and is not an opportunity “to relitigate an issue that was or could have been litigated in the original proceeding.” Shepherd v. Truex, 823 N.E.2d 320, 325–26 (Ind. Ct. App. 2005). And the party must still show how fraud undermined the presentation of their defense. See id. at 326. Secondly, the savings clause also recognizes a trial court’s “inherent power” to “set aside its judgment if procured by fraud on the court.” Stonger, 776 N.E.2d at 357. But this must involve “an unconscionable plan or scheme” to “improperly influence the court’s decision.” Id.
All in all, our trial rules afford parties ample opportunities to oppose summary judgment and challenge a final judgment based on fraud. But in the interest of finality, these opportunities include procedural and substantive requirements. And trial courts cannot excuse any party— including a pro se litigant—from compliance with these constraints. Having laid out the applicable framework, we now turn back to this case to determine whether the trial court improperly granted Liu relief.
B. Liu’s request for relief based on fraud was both untimely and unsupported by any evidence that fraud impacted her defense.
AFC argues that the trial court, by granting Liu relief under Trial Rule 60(B)(3), abused its discretion in three ways: (1) by considering grounds that “could have been raised by a timely motion to correct errors and a timely direct appeal”; (2) by applying the Trial Rule 56 summary judgment standard instead of the Trial Rule 60(B)(3) standard; and (3) by granting relief without Liu showing that fraud prevented her from designating evidence in opposition to summary judgment. Though the first basis for reversal is sufficient to resolve this appeal, we agree with AFC on all three points.
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Conclusion
For the reasons explained above, we reverse the trial court’s decision to grant Liu relief from judgment under Trial Rule 60(B)(3) and remand for the court to reinstate summary judgment for AFC.
Massa, Slaughter, and Molter, JJ., concur.
Goff, J., dissents with separate opinion.
Goff, J., dissenting.
I respectfully dissent.
The Court’s decision today leaves Meng Liu, a non-native English speaker who was unrepresented for most of the proceedings, liable for $163,097.99, despite being the victim of fraud. App. Vol. 2, p. 9. Automotive Finance Corporation (AFC) obtained a summary judgment against Liu based on a forged loan agreement she never signed. No one questions that she is a victim of fraud, so the trial court granted Liu relief from the judgment under Indiana Trial Rule 60(B), and the Court of Appeals affirmed. Because the trial court and Court of Appeals have corrected this fraud, I would not use this Court’s discretionary review under Indiana Appellate Rule 57(H) to reverse a just outcome.
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