Indiana’s top court tossed a $600,000 jury verdict, ruling a teacher's retaliation claim didn’t meet the strict test tied to workers’ comp protections.
On June 24, the Indiana Supreme Court reversed a jury award of $600,000 to a former elementary school teacher who claimed she was forced out of her job for planning to file a workers’ compensation claim.
The case involved Connie Grabowski, a longtime teacher at South Bend Community School Corporation, who said she was injured after a brief hallway collision with a second-grade student. The student’s family had deep ties to the school system: his mother worked there, and his grandmother sat on the board.
Grabowski filled out an internal accident report form, labeled “Worker’s Compensation Accident Report Form,” describing mild injuries to her wrist, ankle, and thigh. Video footage later showed the incident was accidental and not forceful, contradicting her report. The school asked her to revise the documents and apologize to the student and his mother.
Days later, the student’s mother filed a bullying complaint. The school launched a formal investigation, placed Grabowski on paid leave, and eventually offered her a last-chance agreement to stay on staff. It came with strict conditions, including a pay cut and reassignment. Grabowski declined and resigned in June 2016.
She later filed suit, arguing that the school’s actions were retaliation for indicating she might file a workers’ compensation claim. A jury sided with her, awarding $600,000 in damages. But the state’s highest court disagreed, ruling that her case didn’t meet Indiana’s legal standard, which only protects employees who are fired solely because they exercised their right to claim workers’ comp.
Writing for the majority, Justice Geoffrey Slaughter said the record showed the school acted in part to address internal concerns, including the student’s family connections—not simply to avoid liability. That mixed motive disqualified the claim.
There was no discussion of insurance policy terms, but the decision matters to risk and HR teams. It highlights how employers document workplace incidents, especially when they involve people tied to leadership, and how those actions can (or can’t) trigger workers’ comp-related liability. The ruling also offers clarity for insurers assessing whether such employment disputes fall within coverage lines tied to retaliation or compensable injury claims.
The decision underscores just how narrow the line is when employees try to argue retaliation under workers’ comp protections and serves as a cautionary tale for employers and insurance professionals navigating similar internal incident reports.
The case is now closed, with the court ordering judgment entered in favor of the school corporation.
