Massa, J.
This case concerns application of the final judgment rule and the order it brings to civil litigation when consistently applied.
A gifted athlete competed for a coveted spot on the 2020 United States Olympic Team in Track and Field. The team is chosen every four years at a meet known as the Olympic Trials, organized and conducted by USA Track and Field, the sport’s domestic governing body headquartered in Indianapolis. The 2020 Olympic Trials were held in intense heat in Eugene, Oregon in June 2021, as the Olympics were delayed a year due to the Covid pandemic. On the second day of the heptathlon event, Appellant Taliyah Brooks suffered heat related injuries that prevented her from making the Olympic team. She sued USATF, seeking a declaratory judgment to invalidate a release she signed prior to the competition, with an eye toward pursuing tort claims if she prevailed.
The trial court granted summary judgment for USATF and against Brooks, and issued its orders before Brooks brought any tort claims against USATF. Two days after the trial court issued its final judgment, and a few days before the statute of limitations for her tort claims expired, Brooks moved to amend her complaint. The trial court denied her motion. Because Brooks moved to amend after final judgment, we affirm the trial court’s denial of her motion. Moreover, we take this opportunity to clarify that Indiana Trial Rule 15(A) does not apply after final judgment.
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We first address whether a party can amend their complaint after final judgment has been issued. Consistent with long-standing Indiana and federal precedent, we hold a party may not. Therefore, we find the trial court did not abuse its discretion in denying Brooks’ motion to amend her complaint—rather, the trial court had no discretion, and denial was the only appropriate outcome. Then, we clarify that Indiana Trial Rule 15(A) does not apply after final judgment.
I. The Trial Court did not Err in Denying Brooks’ Motion to Amend her Complaint
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As this Court recently explained, “[r]espect for the finality of judgments is . . . 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.” Auto. Fin. Corp. v. Liu, 250 N.E.3d 406, 408 (Ind. 2025). Here, the trial court issued final judgment in favor of USATF, disposing of Brooks’ only operative claim. While both parties have acknowledged the trial court entered final judgment in June 2023, they disagree on whether Brooks could still amend her complaint afterwards. [Footnote omitted.] She could not. Once the trial court issued the Summary Judgment Orders, Brooks’ lawsuit was resolved. There was no longer a live complaint to amend.
Here, Brooks brought a complaint for declaratory and injunctive relief. After protracted litigation, including Brooks’ first partial motion for summary judgment, the parties filed cross-motions for summary judgment. 4 The trial court granted summary judgment for USATF. The trial court’s order states there were “no genuine issues of material fact and that [USATF] is entitled to judgment as a matter of law.” [Footnoteo mitted.] Brooks did not plead any claims that survived the trial court’s ruling, including any cause alleging gross negligence, which would have survived the court’s ruling on the enforceability of the Agreement, and the trial court entered final judgment in finding for USATF as a matter of law, thereby disposing of all issues as to all parties. See Bueter, 776 N.E.2d at 912–13.
No doubt, Brooks acted swiftly in moving to amend two days after the trial court’s Summary Judgment Orders; however, she was still too late, because Indiana law regarding the doctrine of finality is clear. Under our laws, the result would be the same whether Brooks moved to amend one day or two years after final judgment. To find otherwise would convert a bright line rule to a discretionary exercise.
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II. Rule 15(A) Does Not Apply after Final Judgment
USATF further argues the trial court could not grant Brooks’ motion to amend under Rule 15(A) because that rule does not apply when a final judgment has been entered. We agree.
Indiana Trial Rule 15(A) allows a party to “amend his pleading once as a matter of course at any time before a responsive pleading is served.” Once the defendant files its answer, “a party may amend his pleading only by leave of court or by written consent of the adverse party; and leave shall be given when justice so requires.” Id. (emphasis added).
Brooks could have filed her motion to amend her declaratory judgment complaint to add her tort claims against USATF any time prior to the trial court’s entry of final judgment and, pursuant to Ind. Trial Rule 15(A), such motion to amend may well have been granted. However, once the trial court issued summary judgment for USATF, which we have established was a final judgment, Brooks had no option but to file a motion to vacate or set aside the judgment, or separately file her tort claims under a new cause number (and she had several days to do so before the statute of limitations expired). As Brooks failed to pursue these options, and because Rule 15(A) did not apply, the trial court did not abuse its discretion by denying the motion to amend; the trial court had no discretion to abuse.
Conclusion
Our decision is not rooted in this Court’s opinion of the merits of Brooks’ once-prospective claims. We recognize the gravity of Brooks’ allegations against USATF and the impact her heat exhaustion at the Olympic Trials had on her Olympic dreams, which were so close to being realized. Rather, our decision applies and clarifies the procedure for bringing these claims. No doubt, this case involved serious strategic and practical concerns that may have driven counsel’s decisions. But the final judgment rule is clear and cannot be affected by a litigant’s strategic choices. Because Rule 15(A) does not apply after a final judgment, the trial court was correct in its ruling and we affirm.
Rush, C.J., and Slaughter and Molter, JJ., concur.
Goff, J., dissents with separate opinion.
Goff, J., dissenting.
I take no issue with the Court’s holding, as a general proposition, that a party may not amend their complaint after the trial court issues a final judgment. See ante, at 7. But here, in my view, the trial court improperly entered final judgment against the plaintiff in the first place. And without such judgment barring her motion to amend, the plaintiff could have proceeded to trial on her negligence claims. Thus, I respectfully dissent from the Court’s opinion denying relief to the plaintiff here.
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