Sheree Woodson, Appellant-Plaintiff v. Keiandra Jones, Appellee-Defendant (2025)

MEMORANDUM DECISION

[1] Keiandra Jones’ (“Jones”) car was damaged by Sheree Woodson (“Woodson”) in late 2024. In January 2025, Jones filed, in the small claims court, a notice of claim against Woodson. Soon after, Woodson filed a counterclaim against Jones. In June 2025, the small claims court held a bench trial. After the bench trial, the small claims court entered judgment in favor of Jones in the amount of $3,229.00. Woodson, pro se, now appeals the small claims court's judgment.

[2] At the outset, we note that Woodson has chosen to proceed pro se. It is well settled that pro se litigants are held to the same legal standards as licensed attorneys. Dridi v. Cole Kline LLC, 172 N.E.3d 361, 364 (Ind. Ct. App. 2021). Thus, pro se litigants are bound to follow the established rules of procedure and must be prepared to accept the consequences of their failure to do so. Id. “These consequences include waiver for failure to present cogent arguments on appeal.” Id. “We will not become an advocate for a party, nor will we address arguments which are either inappropriate, too poorly developed or improperly expressed to be understood.” Id. (cleaned up).

[3] Additionally, we note that Jones did not file an Appellees’ brief. When an appellee fails to submit an appellate brief, “we will reverse the trial court's judgment if the appellant's brief presents a case of prima facie error.” Front Row Motors, LLC v. Jones, 5 N.E.3d 753, 758 (Ind. 2014) (cleaned up). “Prima facie error in this context is defined as, at first sight, on first appearance, or on the face of it.” Id. (cleaned up).

[4] Woodson argues that the small claims court erred when it entered judgment in favor of Jones because its judgment was “based on insufficient and unreliable evidence.” (Woodson's Br. 6). Specifically, Woodson argues that Jones did not meet her burden of proof and makes multiple challenges to the evidence admitted during the bench trial. However, Woodson has not provided our Court with a transcript of the hearing before the small claims court in violation of Indiana Appellate Rule 9(F)(5), which provides that if “the appellant intends to urge on appeal that a finding of fact or conclusion thereon is unsupported by the evidence or is contrary to the evidence, the Notice of Appeal shall request a Transcript of all the evidence.” A party should designate “all portions of the Transcript necessary to present fairly and decide the issues on appeal.” Ind. Appellate R. 9(F)(5).

[5] Here, Woodson argues that the small claims court erred because its judgment was supported by insufficient evidence. However, Woodson provides us with no avenue to review her claims because she did not request or procure a transcript of the bench trial. The Indiana Supreme Court has addressed an appellant's failure to include a transcript on appeal when factual issues are presented and held that “[a]lthough not fatal to the appeal, failure to include a transcript works a waiver of any specifications of error which depend upon the evidence.” In re Walker, 665 N.E.2d 586, 588 (Ind. 1996) (cleaned up). Consequently, Woodson has waived any argument relying on evidence that challenges the small claims court's judgment on appeal. See Lifeline Youth & Family Serv., Inc. v. Installed Bldg. Products, Inc., 996 N.E.2d 808, 815 (Ind. Ct. App. 2013) (concluding that a party had waived an argument relying on evidence presented at trial where the party had not provided a transcript of the trial on appeal).

[6] Further, Woodson's brief violates a litany of the Indiana Appellate Rules. First, Woodson has failed to comply with Indiana Appellate Rule 46(A)(5), which provides that the statement of the case in a party's brief shall “briefly describe the nature of the case, the course of the proceedings relevant to the issues presented for review, and the disposition of these issues by the trial court[.]” “Page references to the Record on Appeal or Appendix are required in accordance with Rule 22(C).” App. R. 46(A)(5). Here, Woodson's statement of the case does not state the proceedings relevant to the issues presented for review, does not provide the disposition of these issues by the small claims court, does not cite to the record on appeal, and contains argument.

[7] Additionally, Woodson has failed to comply with Indiana Appellate Rule 46(A)(6), which provides that a party's statement of facts “shall describe the facts relevant to the issues presented for review but need not repeat what is in the statement of the case.” “The facts shall be supported by page references to the Record on Appeal or Appendix in accordance with Rule 22(C).” App. R. 46(A)(6)(a). Here, Woodson's statement of facts does not contain citations to the record on appeal and includes argument. Woodson's repeated failures to comply with the appellate rules impedes our review of the issues.

[8] Woodson's most egregious violation is that she has failed to comply with Indiana Appellate Rule 46(A)(8). Specifically, Woodson's brief contains a roughly one-page argument section that does not contain citations to a single authority in support of her arguments. Woodson has waived her arguments on appeal because her arguments fail to make any cogent argument or cite to any relevant authority that supports her claims. See App. R. 46(A)(8)(a) (providing that a party's arguments must be supported by cogent reasoning and “must be supported by citations to the authorities, statutes, and the Appendix or parts of the Record on Appeal relied on, in accordance with Rule 22”). Additionally, Woodson's brief did not provide a standard of review for each issue as required by Indiana Appellate Rule 46(A)(8)(b). We again note that we will not become an advocate for a party, nor will we address arguments that are inappropriate, too poorly developed, or improperly expressed to be understood. See Dridi, 172 N.E.3d at 364.

[9] Concluding that Woodson has waived her arguments on appeal, we affirm the small claims court's judgment.

Affirmed.

Pyle, Judge.

Vaidik, J., and Mathias, J., concur.