May, J.
….
In November 2024, Landlord filed a notice of claim against Anderson alleging that she had failed to pay rent in accordance with their rental agreement.
….
Following the initial hearing, the trial court entered a prejudgment order of possession in favor of Landlord and gave Anderson approximately two weeks to vacate the house. Before that date, Anderson and Landlord entered into an agreement whereby Anderson paid the rent she owed Landlord and Landlord agreed she could stay in the house. Landlord then moved to dismiss the case, and the trial court granted Landlord’s motion to dismiss. Anderson filed a verified petition to prohibit disclosure of her eviction records, and the trial court denied her petition.
….
Anderson contends the trial court erred as a matter of law when it denied her petition because Indiana Code section 32-31-11-3 required the trial court to seal the eviction case record. At the time Anderson filed her petition to seal the record of her eviction case, Indiana Code section 32-31-11-3(a) (2022) provided that, subject to exceptions not applicable here,
if a landlord files an eviction action and:
(1) the eviction action is dismissed by the court:
(A) upon petition of the landlord . . . or otherwise;
* * * * *
the court in which the eviction action was filed, upon motion by the tenant, shall order the clerk of the court and the operator of any state, regional, or local case management system not to disclose or permit disclosure of any records in the case, including the petition by the landlord for possession of the rental unit. In an order issued under this subsection, the court shall direct the clerk of the court to redact or permanently seal the court’s own records related to the eviction action.
(footnote added). Effective July 1, 2025, Indiana Code section 32-31-11-3 was amended to provide that “the court in which the eviction action was filed shall, on its own motion, order” the eviction record to be sealed.
….
Here, the statute required the trial court to seal the eviction record if the one of the conditions listed in Indiana Code section 32-31-11-3(a)(1) was satisfied. See Ind. Code § 32-31-11-3(a) (“the court in which the eviction action was filed . . . shall”) (emphasis added). Anderson satisfied one of those conditions because the case was dismissed after Landlord moved to dismiss it. Therefore, the trial court erred when it denied Anderson’s petition to seal the record.
Conclusion
The trial court erred as a matter of law when it denied Anderson’s petition to seal the record of her eviction case. She satisfied the statutory condition for the record to be sealed, and the trial court was required by statute to seal the record. Accordingly, we reverse the trial court and remand for further proceedings in accordance with this opinion.
Reversed and Remanded.
Altice, J., and Foley, J., concur.