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Gaerte v. Great Lakes Terminal & Transport Corp.

Citations: 506 F. Supp. 2d 271; 2007 U.S. Dist. LEXIS 63277; 2007 WL 2461650Docket: 3:05 CV 141

Court: District Court, N.D. Indiana; August 27, 2007; Federal District Court

Narrative Opinion Summary

This case involves a motion for partial summary judgment filed by the defendant, Great Lakes Terminal Transport Corporation, against the plaintiff, who claims lost wages and corporate profits following an accident. The plaintiff, owning 70% of Gaerte Engines, an Indiana S corporation, argued for damages due to revenue loss post-accident. However, he admitted the decline was partly due to a market downturn. The court granted summary judgment to Great Lakes on the lost wages claim, as the plaintiff continued receiving his salary, which he did not contest. Regarding the corporate profits claim, Indiana law, as interpreted in Benson v. Warble, precludes shareholder-employees from recovering corporate losses. The plaintiff attempted to invoke Bova v. Gary, arguing he could claim damages as an alter ego of the corporation. The court found that the plaintiff did not satisfy the Bova criteria, pointing to his 70% ownership and the lack of evidence showing personal liability for corporate debts or sole decision-making power. Consequently, Great Lakes prevailed, with the court finding no material fact issues warranting trial on these claims.

Legal Issues Addressed

Corporate Profits and Shareholder-Employee Standing

Application: The plaintiff was denied standing to claim corporate losses based on Indiana case law, notably Benson v. Warble, which prohibits such claims.

Reasoning: For the claim concerning lost corporate profits, Great Lakes argued that the plaintiff lacked standing under Indiana law to claim damages for Gaerte Engines' losses.

Exception to Corporate Profit Recovery Under Bova v. Gary

Application: The plaintiff failed to meet the criteria for claiming lost profits, as he did not prove he was the alter ego of his S corporation as required under the Bova exception.

Reasoning: Ultimately, the plaintiff failed to provide sufficient evidence to establish that he is the alter ego of Gaerte Engines, particularly when compared to the plaintiff in Bova.

Lost Wages Claim under Indiana Law

Application: The court granted summary judgment because the plaintiff continued to receive his full salary during his period of injury, waiving any arguments to the contrary.

Reasoning: Great Lakes contends that the plaintiff cannot claim lost wages since he received his full salary from Gaerte Engines during his injury period. The plaintiff failed to respond to this claim, resulting in waiver of any argument against it.

Summary Judgment under Federal Rule of Civil Procedure 56(c)

Application: Summary judgment was granted because the evidence showed no genuine issue of material fact regarding the claims for lost wages and corporate profits.

Reasoning: Summary judgment is warranted when the evidence demonstrates no genuine issue of material fact, allowing the moving party to prevail as a matter of law, as per FED. R. CIV. P. 56(c).