“Sole-Cause or No Cause”: The Indiana Supreme Court Re-anchors Frampton Liability in South Bend Community School Corp. v. Grabowski (2025)

1. Introduction

South Bend Community School Corporation v. Connie Grabowski, No. 24S-CT-395 (Ind. Sup. Ct. June 24, 2025), is the Indiana Supreme Court’s most consequential employment-law opinion since Frampton v. Central Indiana Gas Co. (1973). The Court—speaking through Justice Slaughter—reversed a $600,000 jury verdict entered in favor of a veteran teacher, holding that a plaintiff pursuing a “Frampton claim” must prove that avoidance of workers’-compensation liability was the sole motivating reason for the challenged discharge or constructive discharge. Because the teacher herself attributed the school’s actions partially to “school politics” and familial favoritism, the Court found the “sole-cause” requirement unmet and ordered judgment for the employer as a matter of law.

The dispute pitted:

• Appellant / Defendant: South Bend Community School Corporation (SBCSC), Indiana’s fifth-largest public-school employer;
• Appellee / Plaintiff: Connie Grabowski, a 20-year second-grade teacher who resigned after being offered a “last-chance” agreement following an investigation into alleged bullying of a student who was the grandson of a school-board trustee.

Key issues included the outer limits of Indiana’s narrow exception to employment-at-will for retaliatory discharge, the meaning of “solely” in Frampton, and the evidentiary standard on a Trial Rule 50(A) motion for judgment on the evidence.

2. Summary of the Judgment

The Supreme Court (3-2) granted transfer, vacated a non-precedential Court of Appeals opinion, and:

• Reversed the trial court’s denial of SBCSC’s Rule 50(A) motion;
• Held that the evidence could not support a reasonable inference that Grabowski was discharged solely for her contemplated workers’-comp claim;
• Ordered the trial court to enter judgment for SBCSC.

Justice Goff (joined in part by Justice Molter) dissented, arguing that a jury question existed on “sole causation” and that the majority over-narrowed Frampton.

3. Analysis

3.1 Precedents Cited

• Frampton v. Central Indiana Gas Co., 297 N.E.2d 425 (Ind. 1973) – created the tort of retaliatory discharge when an employee is fired “solely” for exercising a statutory right, especially filing for workers’ comp.
• Baker v. Tremco, Inc., 917 N.E.2d 650 (Ind. 2009) – confirmed constructive-discharge theory under Frampton.
• Meyers v. Meyers, 861 N.E.2d 704 (Ind. 2007) – cautioned that Frampton is a “quite limited exception.”
• Cosme v. Clark, 232 N.E.3d 1141 (Ind. 2024) – restated de novo review standard for Rule 50(A) motions.
• Several Court of Appeals opinions (Purdy, Best Formed Plastics, etc.) and Seventh Circuit cases (Smeigh) on causation and evidence in retaliatory-discharge suits.

Influence on Outcome. The majority treated Frampton’s “solely” language as outcome-determinative, reading subsequent Indiana cases like Purdy to demand exclusive causation. Precedent thus required reversal once the Court accepted that politics or nepotism motivated the school’s conduct even in part.

3.2 Court’s Legal Reasoning

1. Employment-At-Will Framework. Indiana recognizes only three exceptions; Grabowski invoked the third (retaliation for exercising a statutory right).
2. Elements of a Frampton Claim. (i) protected activity; (ii) discharge or constructive discharge; (iii) sole causal link.
3. Sole-Cause Emphasis. The Court re-habitualized trial courts to the “any and all reasons” test: if any legitimate or non-workers’-comp reason co-existed, the cause fails.
4. Application to Facts. Grabowski’s own narrative placed nepotism and public-relations concerns at the heart of SBCSC’s actions. Thus, by definition, workers’-comp avoidance was not the sole cause.
5. Procedural Posture. Because no reasonable jury could find for Grabowski under the “sole-cause” standard, judgment on the evidence was proper.

3.3 Potential Impact

The decision carries ripples across Indiana employment litigation:

• Tightens Plaintiff’s Burden. Plaintiffs must now plead and prove near-monolithic causation. Mixed-motive evidence, once helpful, now kills a Frampton claim.
• Encourages Early Rule 50 Motions. Employers may more confidently seek judgment on the evidence where any alternative motive appears.
• Clarifies Employer Documentation. Accident-report forms alone are insufficient to create protected activity if employers can show concurrent, non-workers’-comp reasons for discipline.
• Public-Sector Nuances. The case illustrates complications where school politics, board relations, or protected classes intersect with workplace-injury rights.
• Future Legislative Response. The dissent’s policy concerns may spur statutory modification to adopt a “motivating factor” or “predominant cause” standard rather than “sole cause.”

4. Complex Concepts Simplified

5. Conclusion

South Bend Community School Corp. v. Grabowski re-centers Indiana’s retaliatory-discharge jurisprudence on a strict reading of Frampton. By elevating “sole causation” from doctrinal language to dispositive rule, the Court has narrowed an already “quite limited” exception to employment-at-will. Plaintiffs must now clear a high evidentiary bar: they must show that their employer’s only motive was to chill the exercise of workers’-comp rights. Defense counsel will invoke this case to defeat claims containing any hint of alternative employer motives. Whether the General Assembly or future courts will soften the standard remains to be seen, but for now the guiding principle in Indiana is unmistakable: a Frampton claim lives or dies on exclusivity of motive—sole-cause or no cause.