The Indiana Court of Appeals issued a ruling on July 29, 2026, in the case of Gregory Brandon v. Caregan Transport, Inc., which involves a wage dispute between a former truck driver and his employer. The court found that Brandon is entitled to $5,535.06 in unpaid wages, but it also upheld the trial court's decision regarding liquidated damages. This ruling is significant for workers seeking to recover unpaid wages and clarifies jurisdictional issues in wage payment claims.
Gregory Brandon, who worked as a truck driver for Caregan Transport from January to May 2020, filed a lawsuit against the company in July 2021 after he claimed he was not paid for several weeks of work. The case was assigned the docket number 25A-PL-02294. Brandon argued that Caregan failed to pay him for miles driven and layovers during his employment, as well as making unauthorized deductions from his wages. The trial court initially ruled that it lacked jurisdiction to hear the case, which prompted Brandon's appeal.
The dispute began when Brandon voluntarily left his job at Caregan Transport. He claimed he was owed wages for the weeks leading up to his departure, totaling $5,535.06. Caregan admitted to failing to pay Brandon for multiple paychecks but contested the amount owed and the nature of the payments. The case eventually reached the Indiana Court of Appeals after Brandon's motion for summary judgment was denied by the trial court.
The court ruled that the trial court erred in concluding it had no jurisdiction over Brandon's wage claim. The ruling emphasized that Indiana courts have the authority to hear wage payment claims under the Wage Payment Statute, which allows employees to seek recovery for unpaid wages. The court stated, "The trial court was authorized by statute to hear wage payment claims," reinforcing the importance of jurisdiction in wage disputes.
Furthermore, the court found that the trial court should have stricken Caregan's late-filed materials opposing Brandon's motion for summary judgment. The court noted that Caregan's response was submitted after the deadline due to a technical error in the electronic filing system. The court stated, "The trial court should have stricken Caregan’s untimely response," indicating that late submissions cannot be considered in summary judgment motions.
As a result, the Indiana Court of Appeals ruled in favor of Brandon, awarding him the unpaid wages he sought. However, the court upheld the trial court's decision regarding liquidated damages, stating that Brandon did not meet the burden of proof to show that Caregan acted in bad faith. The court explained, "the court did not err insofar as it denied summary judgment on Brandon’s request for liquidated damages, as he did not meet his burden on summary judgment to negate Caregan’s claim that it acted in good faith."
This ruling has significant implications for workers seeking to recover unpaid wages. It reinforces the rights of employees under the Wage Payment Statute and clarifies the jurisdictional authority of Indiana courts in wage disputes. The decision also emphasizes the importance of timely filings in legal proceedings, particularly in summary judgment motions.
Looking ahead, it is unclear whether Caregan Transport will appeal this ruling. However, the case serves as a reminder of the legal protections available to employees in wage disputes and the need for employers to comply with wage payment laws. The ruling could also influence future cases involving wage claims and the interpretation of the Wage Payment Statute in Indiana.