Personal Injury Complaint - Auto Accident - Indiana
Before filing: Submit the prescribed Appearance form as a separate filing with this Complaint under Trial Rule 3.1(A). Submit the summons for the clerk to issue, then serve the issued summons and Complaint by an authorized Trial Rule 4 method. Check the filing court’s local instructions.
IN THE [________________________________] COURT OF [________________________________] COUNTY, INDIANA
| Party | Role |
|---|---|
| [PLAINTIFF FULL LEGAL NAME] | Plaintiff |
| v. | |
| [DEFENDANT FULL LEGAL NAME] | Defendant |
Cause No.: [________________________________]
COMPLAINT FOR DAMAGES — MOTOR VEHICLE COLLISION
Plaintiff [PLAINTIFF NAME], by [COUNSEL NAME / SELF-REPRESENTED], alleges against Defendant [DEFENDANT NAME]:
Parties and venue
-
Plaintiff resides in [COUNTY, STATE].
-
Defendant resides or has a principal office in [COUNTY, STATE] and may be served at [SERVICE ADDRESS].
-
This action arises from a motor vehicle collision in [COUNTY], Indiana. The facts supporting this Court's authority to hear the case are [________________________________].
- [COUNTY] is a preferred venue under Indiana Trial Rule 75(A)(3) because the collision occurred here and this complaint seeks damages for injuries relating to the operation of a motor vehicle.
Count I — Negligence
-
On [__/__/____], Plaintiff was [DRIVING / RIDING / WALKING] at [LOCATION AND DIRECTION OF TRAVEL].
-
Defendant was operating [DESCRIBE VEHICLE] at [LOCATION AND DIRECTION OF TRAVEL].
-
The collision occurred when [DESCRIBE VEHICLE MOVEMENTS, ROAD CONDITIONS, SIGNALS, AND POINT OF IMPACT].
-
Defendant owed Plaintiff a duty to use reasonable care in operating the vehicle.
-
Defendant breached that duty by [STATE SPECIFIC ACTS OR OMISSIONS SUPPORTED BY THE FACTS].
-
Defendant's conduct caused the collision and Plaintiff's injuries because [DESCRIBE CAUSAL CONNECTION].
-
Plaintiff suffered [DESCRIBE BODILY INJURIES AND TREATMENT].
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Plaintiff incurred [DESCRIBE MEDICAL EXPENSES, LOST INCOME, PROPERTY DAMAGE, AND OTHER DOCUMENTED LOSSES].
-
Plaintiff also suffered [DESCRIBE PAIN, IMPAIRMENT, OR OTHER NON-ECONOMIC HARM SUPPORTED BY THE FACTS].
Demand for relief
Plaintiff requests judgment against Defendant for compensatory damages proved in this action, costs as allowed by law, and any other appropriate relief.
Jury demand
Plaintiff demands trial by jury on every issue triable of right by jury under Indiana Trial Rule 38(B).
Dated: [__/__/____]
Signature: ___________________________________
Name: [________________________________]
Indiana attorney number, if represented: [________________________________]
Address: [________________________________]
Telephone: [________________________________]
Email: [________________________________]
Sources and references
- Ind. Code § 34-11-2-4(a) requires a general personal injury action to begin within two years after the claim accrues; the collision date alone does not establish accrual.
- Indiana Trial Rules 8, 10, 38, and 75 govern pleadings, the jury demand, and preferred venue. For a motor vehicle collision, Rule 75(A)(3) identifies the county of the accident as a preferred venue.
About this template
- Last updated
- October 24, 2026
- Jurisdiction
- Indiana
- Category
- Personal Injury
Legal authority
- Ind. Code § 34-11-2-4(a) (Personal Injury Limitations Period)
- Indiana Trial Rule 3.1(A) (Appearance at case initiation)
- Indiana Trial Rule 8(A) (Claims and Demand for Relief)
- Indiana Trial Rule 10(G)-(H) (Caption and Numbered Allegations)
- Indiana Trial Rule 38(B) (Jury Demand)
- Indiana Trial Rule 75(A)(3) (Motor Vehicle Accident Venue)
Personal injury cases are brought by people who were hurt because of someone else's carelessness: car crashes, slip and falls, defective products, and more. Demand letters, settlement agreements, and court filings in these cases have to document the injuries, the medical treatment, the lost income, and the exact legal basis for holding the other side responsible. Well-prepared paperwork is what drives higher settlements and forces insurers to take the claim seriously.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
The statutes this template relies on are listed under Legal authority.
Indiana Trial Rule 3.1(A) (checked October 24, 2026): "Pursuant to Trial Rule 3.1(A), an appearance form shall be filed by the initiating party at the time an action commenced."
Indiana Trial Rules 4 and 86(B)(2) (checked October 24, 2026): "service of the initial complaint or equivalent pleading and the summons is made by the filer using a method provided for by T.R. 4.1 through 4.17"
Indiana Trial Rule 75(A)(1) (checked October 19, 2026): "the county where the greater percentage of individual defendants included in the complaint resides, or, if there is no such greater percentage, the place where any individual defendant so named resides"
Indiana Trial Rule 75(A)(3) (checked October 19, 2026): "the county where the accident or collision occurred, if the complaint includes a claim for injuries relating to the operation of a motor vehicle or a vehicle on railroad, street or interurban tracks"
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