Which Dictionary Matters?

We recently told you that the Indiana Supreme Court prefers standard dictionaries to legal dictionaries when defining terms. A June 30, 2011 decision from the Indiana Court of Appeals in Enhanced Network Solutions Group, Inc. v. Hypersonic Technologies Corp., ___ N.E.2d ___ (Ind. Ct. App. 2011), Cause No. 02A03-1011-PL-609, demonstrated that it does not subscribe to the same philosophy

In this case, the Court was defining the terms “solicit” and “induce” for the purposes of a contractual non-solicitation clause. The Court noted that no Indiana case law had discussed the precise meaning of these terms, so it looked to a dictionary definition. But rather than relying on a standard dictionary, the Court relied solely on Black’s Law Dictionary.

We aren’t taking the time to determine whether a different dictionary could have led to a different result. But we do think it is worth suggesting that you cite legal dictionaries to the Court of Appeals, and standard dictionaries to the Supreme Court.

Brad A. Catlin
Price Waicukauski & Riley, LLC
Learn more about Brad and contact us
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