London Irons, Appellant-Defendant v. Indiana Finance Financial Corp, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Statement of the Case

[1] London Irons (“Irons”), pro se, appeals the small claims court's judgment entered in favor of Indiana Finance Financial Corp (“IFFC”). Irons makes multiple arguments, and we consolidate and restate her argument as whether the small claims court clearly erred when it entered judgment in favor of IFFC. Concluding that the small claims court did not clearly err, we affirm the small claims court's judgment.

[2] We affirm.

Issue

Whether the small claims court clearly erred when it entered judgment in favor of IFFC.

Facts

[3] In December 2017, Irons purchased a 2008 Pontiac G6 (“the car”) from Oak Motors. Irons and Oak Motors entered into a motor vehicle retail installment sales contract (“the contract”). In the contract, Irons agreed to pay $13,300.10 for the car, which included a $1,000 down payment. Irons further agreed to make monthly payments. After both parties had signed the contract, Irons received a copy of the contract. At that time, the contract contained an assignment provision that was left blank (“the copy of the contract with the blank assignment provision”). Later that day, Oak Motors assigned its rights under the contract to IFFC and then filled in that assignment information on the contract (“the copy of the contract with the IFFC assignment provision”).

[4] In the spring of 2021, Irons stopped making payments on the contract.¹ Thereafter, IFFC repossessed and sold the car. After the sale, IFFC provided Irons with a settlement statement showing that her account had a deficiency balance.² Irons and IFFC were in contact regarding the car and, in August 2022, an employee at IFFC emailed Irons the copy of the contract with the blank assignment provision. Irons did not make any subsequent payments on the contract.

[5] In June 2025, IFFC filed a notice of claim against Irons. In its notice of claim, IFFC alleged that Irons owed it $4,326.27. IFFC attached the copy of the contract with the IFFC assignment provision. IFFC also attached an affidavit of debt in which it averred that the unpaid balance on Irons’ account was $4,326.27 and that Irons’ last payment had been received in May 2021.

[6] In July 2025, Irons filed a motion to dismiss the notice of claim. She specifically argued that the case should be dismissed under Trial Rule 12(B)(6) and Small Claims Rule 4. Irons argued, in relevant part, that IFFC did not have standing to bring the claim because the version of the contract that contained the IFFC assignment provision had never been given to her prior to the filing of the case. Further, Irons included as exhibits: (1) the August 2022 email from an IFFC employee with an attachment containing the copy of the contract with the blank assignment provision; (2) the copy of the contract with the blank assignment provision that had been attached to the email; and (3) the copy of the contract with the IFFC assignment provision. Thereafter, the small claims court issued an order in which it stated that it would hear Irons’ motion to dismiss on the day of the hearing.

[7] Two days later, Irons filed a counterclaim against IFFC. Irons asserted that she had a claim against IFFC for “misrepresentation and the improper filing of a debt collection claim using an altered version of a contract that differs from the original provided to [Irons] in 2022.” (App. Vol. 2 at 34). Irons requested $2,000 in damages to “compensate for the burden and cost of defending against this improper claim[.]” (App. Vol. 2 at 34).

[8] In August 2025, the small claims court held a hearing. Irons represented herself at the hearing, and IFFC was represented by counsel. At the hearing, Irons testified that she had never seen the copy of the contract with the IFFC assignment provision before the filing of the case and that the version of the contract she had received from IFFC in August 2022 did not contain the IFFC assignment provision. Irons testified that she believed that the contract had been altered and that she did not owe IFFC any money. Irons requested that the small claims court dismiss the case due to a lack of standing because IFFC had “failed to provide any explanation that is valid.” (Tr. Vol. 2 at 28).

[9] IFFC's counsel explained to the small claims court that Oak Motors had assigned the contract to IFFC immediately after the contract had been signed by Oak Motors and Irons. IFFC noted that it had attached the IFFC assignment provision contract to its notice of claim. When the small claims court asked IFFC why, in the August 2022 email, it had sent Irons a version of the contract without the IFFC assignment provision, IFFC responded that Irons had been “mistakenly sent” the copy of the contract with the blank assignment provision instead of the copy of the contract with the IFFC assignment provision. (Tr. Vol. 2 at 25). IFFC also provided the small claims court with a copy of a settlement statement generated by IFFC after it had repossessed and sold Irons’ car.

[10] Irons admitted that her car had been repossessed, that IFFC had given her notice of that repossession, and that she had been communicating with IFFC. Irons also agreed that she had seen and received a letter from IFFC providing that the car had been sold. The small claims court explained to Irons that a party could assign the contract to another party at any time and that it did not require her consent. Additionally, the small claims court acknowledged the fact that Irons was arguing that she had not received the copy of the contract with the IFFC assignment provision but noted that it had been attached to IFFC's notice of claim and had been submitted by Irons as an exhibit. Ultimately, the small claims court told Irons that it found IFFC's explanation of why she had not received the copy of the contract with the IFFC assignment provision in August 2022 to be a valid explanation.

[11] At the conclusion of the hearing, the small claims court entered judgment in favor of IFFC in the amount of $4,326.27. In its written order, the small claims court also found in favor of IFFC on Irons’ counterclaim.

[12] Thereafter, Irons filed a motion to correct error. In her motion to correct error, Irons argued, in relevant part, that the small claims court had not ruled on her motion to dismiss or her counterclaim and that she had not been given an opportunity to present her issues during the hearing. The small claims court denied Irons’ motion to correct error. In its order, the small claims court noted that it had considered all of Irons’ motions, that by ruling in favor of IFFC, Irons’ motion to dismiss was also denied, and that both parties had the opportunity to present evidence.

[13] Irons now appeals.

Decision

[14] At the outset, we note that Irons has chosen to proceed pro se. It is well settled that pro se litigants are held to the same legal standards as licensed attorneys. Basic v. Amouri, 58 N.E.3d 980, 983 (Ind. Ct. App. 2016), reh'g denied. 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. at 983-84. “These consequences include waiver for failure to present cogent arguments on appeal.” Id. at 984. “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.” Dridi v. Cole Kline LLC, 172 N.E.3d 361, 364 (Ind. Ct. App. 2021) (internal quotation marks and citation omitted).

[15] We also note that IFFC 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).

[16] “Judgments in small claims actions are ‘subject to review as prescribed by relevant Indiana rules and statutes.’ ” Hetty Incorporated v. Weems, 237 N.E.3d 701, 704 (Ind. Ct. App. 2024) (quoting Ind. Small Claims Rule 11(A)), reh'g denied. “We review facts from a bench trial under the clearly erroneous standard.” Hetty, 237 N.E.3d at 704 (cleaned up). “The small claims court is the sole judge of the evidence and the credibility of witnesses, and on appeal we neither reweigh the evidence nor assess the credibility of the witnesses.” Heartland Crossing Found., Inc. v. Dotlich, 976 N.E.2d 760, 762 (Ind. Ct. App. 2012). “This deferential standard of review is particularly important in small claims actions, where trials are designed to speedily dispense justice by applying substantive law between the parties in an informal setting.” Berryhill v. Parkview Hosp., 962 N.E.2d 685, 689 (Ind. Ct. App. 2012) (cleaned up). Although the method of proof may be informal, the party bearing the burden of proof must demonstrate that it is entitled to the recovery sought. Spainhower v. Smart & Kessler, LLC, 176 N.E.3d 258, 263 (Ind. Ct. App. 2021), reh'g denied, trans. denied.

[17] In addition, we note that Irons is appealing from the small claims court's denial of her motion to correct error. We will reverse a denial of a motion to correct error only for an abuse of discretion. In re G.R., 863 N.E.2d 323, 325 (Ind. Ct. App. 2007). “An abuse of discretion occurs when the [small claims] court's decision is against the logic and effect of the facts and circumstances before the court or if the court has misinterpreted the law. Id. at 325-26.

[18] The crux of Irons’ argument is that the small claims court clearly erred when it entered judgment in favor of IFFC. We disagree.

[19] Our review of the record reveals that the small claims court did not clearly err when it found in favor of IFFC on its notice of claim and on Irons’ counterclaim. There is no dispute that Irons and Oak Motors entered into the contract. Irons agreed to pay $13,300.10 for the car in monthly payments, and Oak Motors then assigned its rights under the contract to IFFC. Irons failed to make all her required payments, and, as a result, the car was repossessed and sold. The small claims court viewed both the copy of the contract with the IFFC assignment provision and the copy of the contract with the blank assignment provision at trial and heard argument from IFFC and Irons regarding the contract. Ultimately, the small claims court weighed the evidence before it and ruled in favor of IFFC. Irons’ arguments amount to a request to reweigh evidence and judge the credibility of the witnesses, which we will not do. See Heartland, 976 N.E.2d at 762. Accordingly, we affirm the small claims court's judgment.

[20] Affirmed.³

FOOTNOTES

1.   The record is unclear as to whom Irons made payments.

2.   Although IFFC presented a copy of the settlement statement to the small claims court, it was not entered into evidence. Irons did not include a copy of this document in her appendix.

3.   Irons argues that IFFC “failed to establish a valid chain of assignments, [that] it lacked standing to enforce the contract, and [that] the judgment [wa]s void[.]” (Irons’ Br. 10). In support of this argument, Irons cites to McEntee v. Wells Fargo Bank, N.A., 970 N.E.2d 178 (Ind. Ct. App. 2012), which is a case that contains no discussion of standing. Thus, Irons has made no cogent argument pointing to any cases or authorities that support this claim. Therefore, she has waived the argument on appeal. See Ind. Appellate Rule 46(A)(8)(a). Irons also makes a conclusory argument that the small claims court violated her due process rights when it did not rule on her motion to dismiss and counterclaim. However, our review of the record reveals that the small claims court, in its judgment order, ruled in favor of IFFC on Irons’ counterclaim. Further, by entering judgment in favor of IFFC on its notice of claim, the small claims court had also denied Irons’ motion to dismiss. To the extent that Irons argues that she was denied a meaningful opportunity to be heard, we note that she made all of her arguments before the small claims court at trial.

Pyle, Judge.

Bradford, J., and Kenworthy, J., concur.