Gerard Kirsch became injured while building a parking structure adjacent to Calvary Temple Church’s parking lot. Kirsch alleged Calvary’s negligence caused his injury, and Calvary argued I.C. § 34-31-7-2 determined its duty to Kirsch. The Vanderburgh Superior Court disagreed, finding that land devoted for a parking structure was not used “primarily for worship services” as the statute required. The Court of Appeals affirmed. Calvary Temple Church of Evansville, Inc. v. Gerard A. Kirsch, 232 N.E.3d 1182 (Ind. Ct. App. 2024), vacated. The Indiana Supreme Court has granted Calvary Temple Church’s petition to transfer and assumed jurisdiction over the case.