Jayla Anderson v. Advantix Development Corporation - Eviction Record Sealing
Summary
The Indiana Court of Appeals reversed and remanded a trial court's decision denying a petition to seal eviction records. The appellate court found prima facie error in the trial court's denial, potentially impacting how eviction records are handled in Indiana.
What changed
The Indiana Court of Appeals, in the case of Jayla Anderson v. Advantix Development Corporation, reversed and remanded a lower court's decision that denied a tenant's petition to seal her eviction record. The appellate court determined that the trial court erred in its denial, applying a less stringent standard of review due to the appellee's failure to file a brief. This decision suggests a potential shift in the accessibility of eviction records in Indiana.
This ruling implies that individuals seeking to seal eviction records may have a stronger basis for appeal if their initial petitions are denied. Compliance officers in property management or legal departments should review their internal procedures for handling eviction record sealing requests and be prepared for potential challenges to prior denials. While no specific compliance deadline is mentioned, legal teams should be aware of this precedent for future cases.
What to do next
- Review internal policies regarding the sealing of eviction records.
- Consult with legal counsel on the implications of this ruling for ongoing and past eviction cases.
- Prepare to address potential new filings or appeals related to eviction record sealing.
Source document (simplified)
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Top Caption Disposition [Combined Opinion
by Judge May](https://www.courtlistener.com/opinion/10804906/jayla-anderson-v-advantix-development-corporation-ama-for-34-e-marion-lp/about:blank#o1) The text of this document was obtained by analyzing a scanned document and may have typos.
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March 6, 2026 Get Citation Alerts Download PDF Add Note
Jayla Anderson v. Advantix Development Corporation a/m/a for 34 E Marion LP
Indiana Court of Appeals
- Citations: None known
- Docket Number: 25A-EV-01738
- Judges: Altice, May, Foley
Disposition: Reversed and Remanded
Disposition
Reversed and Remanded
Combined Opinion
by Judge May
FILED
Mar 06 2026, 8:57 am
CLERK
Indiana Supreme Court
Court of Appeals
and Tax Court
IN THE
Court of Appeals of Indiana
Jayla Anderson,
Appellant-Defendant
v.
Advantix Development Corporation a/m/a
for 34 E Marion LP,
Appellee-Plaintiff
March 6, 2026
Court of Appeals Case No.
25A-EV-1738
Appeal from the Grant Superior Court
The Honorable Jason D. McVicker
Trial Court Cause No.
27D03-2411-EV-501
Opinion by Judge May
Judges Altice and Foley concur.
May, Judge.
Court of Appeals of Indiana | Opinion 25A-EV-1738| March 6, 2026 Page 1 of 5
[1] Jayla Anderson argues the trial court erred as a matter of law when it denied
her petition to seal her eviction record. We reverse and remand.
Facts and Procedural History
[2] Anderson rented a house on Walnut Street in Marion, Indiana, from Advantix
Development Corporation a/m/a 34 E Marion LP (“Landlord”). 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. Landlord
sought possession of the real estate and monetary damages. The trial court
scheduled an initial hearing to determine whether a prejudgment order of
possession should be issued and a second hearing for the trial court to hear
evidence and enter a final judgment.
[3] 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.
Discussion and Decision
[4] Initially, we note Landlord did not file an appellee’s brief. “In such cases, we
need not develop an argument for the appellee and we apply a less stringent
Court of Appeals of Indiana | Opinion 25A-EV-1738| March 6, 2026 Page 2 of 5
standard of review. We may reverse if the appellant is able to establish prima
facie error, which is error at first sight, on first appearance, or on the face of it.”
Wharton v. State, 42 N.E.3d 539, 541 (Ind. Ct. App. 2015) (internal citation
omitted). However, even in the absence of argument from the appellee, we are
still obligated “to correctly apply the law to the facts in the record in order to
determine whether reversal is required.” Id.
[5] 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.
Court of Appeals of Indiana | Opinion 25A-EV-1738| March 6, 2026 Page 3 of 5
(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.
[6] “Interpretation of a statute is a question of law which we review de novo.”
Taylor v. State, 7 N.E.3d 362, 365 (Ind. Ct. App. 2014). “When the statutory
language is clear and unambiguous, we give effect to its plain and ordinary
meaning.” Pierce v. State, 29 N.E.3d 1258, 1265 (Ind. 2015). “The use of the
word shall is construed as mandatory language, that which creates a statutory
right to a particular outcome after certain conditions are met.” Marshall v. State,
52 N.E.3d 41, 44 (Ind. Ct. App. 2016). 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
[7] 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.
Court of Appeals of Indiana | Opinion 25A-EV-1738| March 6, 2026 Page 4 of 5
[8] Reversed and Remanded.
Altice, J., and Foley, J., concur.
ATTORNEYS FOR APPELLANT
Megan Stuart
Indianapolis Indiana
Christopher C. Baumgartner
Indiana Legal Services
Fort Wayne, Indiana
Court of Appeals of Indiana | Opinion 25A-EV-1738| March 6, 2026 Page 5 of 5
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