March 31, 2026

7th Circuit Court of Appeals
Close Armstrong, LLC, et al. v. Trunkline Gas Company, LLC
No. 24-1630

Civil. Appeal from the U.S. District Court for the Northern District of Indiana, Judge Damon R. Leichty. Affirms the district court’s grant of partial summary judgment to Trunkline. Holds Indiana law does not require unexercised, future rights under a floating easement to be fixed to a defined location, and concludes Trunkline’s remaining rights to install additional pipelines or alter routes remain unfixed because they have not been exercised; the court also declines to certify the question to the Indiana Supreme Court, finding sufficient existing law to resolve the issue with certainty. Judge Jackson-Akiwumi authored the opinion. Judges Easterbrook and Maldonado concur.

7th Circuit Court of Appeals
William Clyde Gibson III v. Ron Neal
No. 25-2779

Civil. Appeal from the U.S. District Court for the Southern District of Indiana, Judge Jane Magnus-Stinson. Reverses the district court’s transportation order and remands for further proceedings. Holds the district court abused its discretion by ordering Gibson transported for brain imaging under the All Writs Act because he failed to show the requested testing had a sufficient nexus to admissible evidence in support of equitable tolling or any habeas claim, as required by Shoop v. Twyford; the court further concludes Gibson did not adequately explain how the scans would advance his argument that mental health issues prevented timely filing of his habeas petition. Judge Scudder authored the opinion. Judges Lee and Pryor concur.

Indiana Court of Appeals
Travis S. Chandler v. State of Indiana
No. 25A-CR-2553

Criminal. Appeal from the Brown Circuit Court, Judge Mary Wertz. Affirms the denial of Chandler’s petition to file a belated appeal and remands with instructions to permit a belated notice of appeal. Holds the trial court did not abuse its discretion in denying relief under Post-Conviction Rule 2 because belated appeals are not available for probation revocation orders under controlling Indiana Supreme Court precedent; however, concludes extraordinarily compelling reasons justify resurrecting Chandler’s forfeited appeal where he timely communicated his desire to appeal, the failure resulted from counsel not hearing him, and he acted diligently once the issue was discovered. Judge Felix authored the opinion. Judges May and Mathias concur. Appellant’s attorney: Kurt A. Young, Nashville, Indiana. Appellee’s attorneys: Office of the Indiana Attorney General.

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