When a parent dies without leaving a will, disputes among family members can become complicated, particularly when an estate includes property in different states. In Indiana, two half-siblings became involved in a prolonged legal battle over their late father’s estate, including real estate in Indiana and California. Although they eventually reached a mediated settlement, disagreements over its terms led to further court proceedings and a substantial financial penalty for the brother.In a November 13, 2026 opinion, the Indiana Court of Appeals upheld sanctions of $177,852.86 against Michael W Clark. The ruling in Michael Clark v. Elisa Mrozinski, available on Justia, found no abuse of discretion in the trial court’s decision to penalise him for violating a settlement agreement and an earlier court order.
Dispute began after father’s death
According to the court’s opinion, Clark and Elisa Mrozinski were half-siblings and children of James L. Clark, who died without a will on September 8, 2021. Mrozinski had previously served as her father’s power of attorney and was appointed personal representative of his estate after his death.Clark filed a legal action in September 2021 seeking an accounting of Mrozinski’s actions while acting as his father’s power of attorney. An estate case was also opened in Indiana, while separate proceedings were initiated in California to handle property located there.The dispute later expanded to include TransAmerican, Inc., a corporation owned by their father and managed by Mrozinski. Clark filed another action in 2023 seeking access to the company’s corporate records. That case was subsequently consolidated with the existing proceedings.
Siblings reached settlement over properties
After several years of litigation, the siblings participated in mediation on July 9, 2024, and signed a settlement agreement. Under its terms, the estate was to transfer certain California real estate to Clark, while he agreed to purchase certain Indiana real estate from the estate.Disagreements emerged soon after the agreement was signed. Both siblings accused the other of failing to fulfil their obligations. In August 2024, they filed separate motions asking the court to enforce the settlement, with Clark alternatively requesting that it be terminated.On September 16, 2024, the trial court rejected Clark’s request and directed both parties to proceed in good faith under the agreement. It clarified that disputes concerning the California property would be decided by the California court, while it retained authority over the remaining claims. Clark subsequently filed objections in the California estate proceedings, challenging aspects of the settlement and arguing that it was unenforceable.
Court imposes $177,852 in sanctions
Mrozinski later asked the Indiana court to hold Clark in contempt, arguing that his objections in California violated the September 2024 order and the settlement agreement. The California court rejected his objections in May 2025.In October 2025, the Indiana trial court found that Clark had knowingly and willingly violated its earlier order. It determined that his failure to comply had caused Mrozinski and the entities she represented to incur $117,655.50 in additional taxes, insurance and security expenses. The court also included $51,617.75 in attorney fees and another $8,579.61 in expenses, bringing the total to $177,852.86. After Clark filed a motion to correct error, the court amended its order in January 2026 but left the sanctions in place.Clark challenged the decision on appeal, arguing that he had not acted in bad faith and had not received sufficient notice that damages would be considered at the hearing. The appeals court rejected his arguments concerning the sanctions hearing. It found that the earlier order clearly required him to comply with the settlement and that he had sufficient notice that financial damages and attorney fees were being sought. The court also noted that Clark had not presented a sufficiently developed argument challenging the amount or type of sanctions.
Appeals court upholds sanctions
On November 13, 2026, the Indiana Court of Appeals affirmed the sanctions of $177,852.86 against Clark. It also remanded the case for the trial court to consider whether Mrozinski could recover additional attorney fees incurred during the appeal. The appeals judges declined to award appellate attorney fees themselves, finding that Clark’s procedural errors did not meet the required standard for such an award.The decision leaves the original sanctions intact while allowing the lower court to consider further legal costs. It highlights how disputes over family estates can continue even after relatives reach a settlement, particularly when one party challenges the agreement or fails to follow court orders.