Opinions August 26, 2025

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Indiana Court of Appeals
In the Matter of the Guardianship of Zachary Graykowski; Members Source Credit Union v. Zachary Graykowski
25A-GU-526
Guardianship. Reverses the Lake Circuit Court’s order finding Members Source Credit Union in contempt for violating a guardianship order. Finds the trial court abused its discretion by finding that Members Source willfully violated the order. Also finds that given the lack of clarity in the guardianship order and the erroneous letters of guardianship, Members Source did not willfully disobey the court’s order and cannot be held in contempt of court. Attorneys for appellant: Kevin Steele, Bryan Bott. Attorney for appellee: John Hughes.

Citizens Action Coalition of Indiana v. Duke Energy Indiana, LLC, and Indiana Utility Regulatory Commission
24A-EX-1348
Administrative. Reverses a decision of the Indiana Utility Regulatory Commission allowing Duke Energy Indiana, LLC to increase utility rates on Hoosiers so Duke Energy could recoup costs to clean up toxic coal ash in Indiana created by Duke Energy’s fossil-fuel-based services. Finds that a direct injury to a member of an association is a direct injury to the association itself when that injury is related to the purposes of the association, and, therefore, Citizens Action Coalition has standing to prosecute this appeal. Also finds the IURC impermissibly applied the relevant Indiana statutes retroactively when it permitted Duke Energy to increase rates on Hoosiers to recover costs to comply with federal mandates that were promulgated prior to the effective date of those statutes. Remands with instructions for the IURC to either reconsider Duke Energy’s application in a manner that is consistent with this opinion or, if that is not possible, dismiss the application. Attorney for appellant: Jennifer Washburn. Attorneys for appellees: Elizabeth Heneghan, Liane Steffes, Peter Rusthoven, Nicholas Kile, Lauren Box, Kian Hudson, Beth Heline, Jeremy Comeau, John Oosterhoff, Attorney General Todd Rokita.

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