MCLACHLAN v. INDIANA DEPARTMENT OF CORRECTION (2026)

Court of Appeals of Indiana.

Sara MCLACHLAN, Appellant-Plaintiff v. INDIANA DEPARTMENT OF CORRECTION, Appellee-Defendant

Court of Appeals Case No. 26A-PL-439

Decided: October 01, 2026

Attorneys for Appellant: William R. Groth, Bowman Legal Services, LLC, Indianapolis, Indiana, Julia Welsh, Federal Community Defender Office, Philadelphia, Pennsylvania Attorneys for Amicus Curiae Indianapolis Monthly Meeting of Friends, Inc.: Jennifer Westerhaus Adams, Jonathan D. Mattingly, Mattingly Burke Cohen & Biederman LLP, Indianapolis, Indiana Attorneys for Appellee: Theodore E. Rokita, Attorney General of Indiana, Tyler Banks, Section Chief, Capital and Habeas Litigation, Indianapolis, Indiana

MEMORANDUM DECISION

[1] The trial court entered summary judgment for the Indiana Department of Correction on Sara McLachlan's complaint to compel the disclosure of public records. There is no dispute that McLachlan's complaint sought the disclosure of at least some public records that the DOC had redacted. According to Indiana Code section 5-14-3-9(h) (2026): “if the complaint alleges that a public agency denied disclosure of a public record by redacting information in the public record, the court shall conduct an in camera inspection of the public record with the redacted information included.” (Emphasis added.)

[2] The trial court has not conducted an in-camera inspection of the relevant public records. We therefore vacate the trial court's entry of summary judgment for the DOC and remand with instructions for the trial court to conduct the statutorily required inspection of the relevant public records. Once the trial court has conducted that inspection, the trial court shall enter an appropriate order.

[3] We exercise our authority under the Indiana Appellate Rules to stay this appeal pending the trial court's compliance with this decision. See Ind. Appellate Rule 37.

[4] Vacated and remanded with instructions.

Mathias, Judge.

Tavitas, C.J., and DeBoer, J., concur.

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