C.J.W. v. T.H. — Five-year adoption bar measured at judgment
The Indiana Court of Appeals held that a five-year criminal-history bar to adoption is measured when the court grants the petition, not when the petition is filed.
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Family Law
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Walls v. Walls — Dissolution decree required recalculation
The Indiana Court of Appeals ordered recalculation of provisional child support and several marital assets while affirming a 55/45 division, custody ruling, and most valuations.
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In re B.E. — Unfinished services did not defeat termination
The Indiana Court of Appeals affirmed termination of parental rights where the father had nearly ten months outside custody to complete offered services but did not do so.
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In re K.J. — CHINS finding required more than possible return to mother
The Indiana Court of Appeals reversed a CHINS adjudication because the child was receiving needed services in her father’s care and a possible return to mother did not establish a need for coercive intervention.
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A.T. v. J.T. — Protective-order extension lacked a present threat
The Indiana Court of Appeals reversed a protective-order extension because old statements and full compliance did not prove a present, credible threat of continuing harm.
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Carrell v. Schurman — Custody findings and relocation burdens required remand
The Indiana Court of Appeals remanded a relocation and custody order because it lacked mandatory findings and placed the initial relocation burden on the wrong parent.
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Siddique v. Siddique — LLC asset liens vacated but discovery sanctions upheld
The Indiana Court of Appeals held that a dissolution court may lien a spouse’s LLC interests but not property owned by the LLCs, while upholding severe sanctions for persistent discovery violations.
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Rose v. Rose — Extended unemployment warrants new support review
The Indiana Court of Appeals held that prolonged unsuccessful job searching can materially change the assumptions behind stipulated income used for child support.
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In re Adoption of J.L.P. — Court dispenses with father’s consent
The Indiana Court of Appeals affirmed an adoption without the father’s consent based on his prolonged failure to communicate and found no due-process violation.
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Wilson v. Mann — Insurance agreement substantially complied with support order
The Indiana Court of Appeals erased a $20,726 arrearage because the parents’ performed agreement to substitute health insurance for weekly support substantially complied with the decree.
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S.H. v. DCS — Court mandates dismissal after late CHINS disposition
The Indiana Court of Appeals held that missing the 30-day CHINS dispositional deadline requires dismissal without prejudice when a timely motion is filed and no continuance extended the deadline.
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Klos v. Klos — Court requires parenting-time findings but limits fraud remedies
The Indiana Court of Appeals remanded for parenting-time findings while affirming custody and the denial of enhanced remedies for fraud in a dissolution case.