The Indiana Court of Appeals, on Thursday, scrapped $3,800 of a landlord’s earlier award after finding that TRS99 LLC had not sent the former tenant a mandated damage list. The decision leaves the landlord, Bruce Skiles, with a $2,400 payment for unpaid rent and no claim for repair costs.
Skiles had sued ex‑tenant John Tuttle in February, alleging that the January 2026 move‑out left the unit with rotting food, cigarette odor, and damaged fixtures. Tuttle had been behind on rent since January 2025, owing $2,400 when the lease ended, and the trial court awarded him $6,200—$2,400 for rent, $2,900 for repairs, and $900 for a dumpster.
Indiana law requires landlords to deliver an itemised damage list within 45 days of a tenant’s departure, and to return the security deposit after deductions. Skiles admitted he never sent the notice or the list, a fact that the appellate judges deemed fatal for any repair claim.
The appeals court also denied the landlord’s counter‑claim that Tuttle had failed to provide a written mailing address, since the issue was not raised at trial. Tuttle’s own request for compensation for lost belongings was dismissed for lack of evidence, leaving him with no recovery.
With the $3,800 removed, the landlord’s total award is now $2,400, and the case is closed. The judgment underscores the importance of following Indiana’s notice requirements in landlord‑tenant disputes.