Per curiam.
We agree with the Court of Appeals that a parent is not entitled to dismissal of a termination-of-parental-rights (“TPR”) petition due to the juvenile court’s failure to complete a hearing within the statutorily required 180 days, where the parent affirmatively waived that requirement, thus inviting the alleged error for which she seeks dismissal. Accordingly, we affirm.
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Mother presents Issue 1 as “[w]hether the juvenile court erred in denying Mother’s motion to dismiss when the termination hearing was not completed within 180 days of the filing of the termination petitions[.]” Appellant’s Br. at 5. She argues that “Indiana statutory law requires dismissal of a TPR case if a hearing on a TPR petition is not completed by one hundred eighty (180) days after the filing of the termination petition” and “[t]he juvenile court erred by not dismissing the TPR proceeding since the proceeding did not conclude within the statutorily mandated one hundred eighty days.” Id. at 21, 24.
The hearing was completed more than 180 days after the filing of the TPR petitions. The record shows that at a pre-trial conference on June 25, 2018, the court scheduled the hearing for half-day sessions on September 26 and October 10, 2018, without objection by Mother’s counsel. The order summarizing the June 25 conference found, “Parties waive the 180 day requirement.” Appellant’s App. Vol. 2 at 75 (emphasis added).
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Mother invited the Court of Appeals to follow language in two child-in-need-of-services (“CHINS”) cases which Mother cites for the proposition that statutory time limits are strict and mandatory and cannot be waived: In re J.R., 98 N.E.3d 652 (Ind. Ct. App. 2018), trans. not sought; and In re T.T., 110 N.E.3d 441 (Ind. Ct. App. 2018), trans. not sought. Both addressed the statute governing CHINS hearings. It provides the juvenile court shall complete a factfinding hearing within 60 days after the CHINS petition is filed, though the court may extend the time to complete the hearing for an additional 60 days if all parties consent to the additional time; it also provides that if the hearing is not held within those times, the court, on motion, “shall dismiss” the case without prejudice. I.C. § 31-34-11-1.
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We disagree with the first part of the Court of Appeals’ analysis to the extent it suggests that because CHINS cases and TPR cases are governed by different statutes, appellate opinions decided under the CHINS statute are ipso facto inapplicable in deciding TPR cases, including issues related to deadlines for hearings. Given the statutes’ similarity, opinions decided under one statute should inform a court when applying the other, as the following analysis shows.
J.R. and T.T. are easily distinguished from Mother’s case. In J.R., “both parents timely objected to the extension of the factfinding deadline beyond the initial sixty days and moved to dismiss before the final hearing was held.” In re M.S., 140 N.E.3d 279, 283-84 (Ind. 2020). That is not the case with Mother, who affirmatively waived the 180-day requirement and did not object until after the hearing was well under way. And the facts set forth in T.T. “gave no reason for DCS’s request for continuance: the mother in that case simply acquiesced.” Id. at 284. In the present case, Mother did not simply acquiesce; she affirmatively waived the 180-day requirement. Accord id. (noting the parent in M.S. “moved for a continuance for a good reason” and “also explicitly waived both the sixty and 120-day periods.”).
Moreover, in light of our opinion in M.S., J.R. and T.T. might be argued and resolved differently if decided today. In M.S., we held that despite the deadlines in the CHINS statute, Indiana Trial Rule 53.5 allows a court, for good cause shown, to continue a hearing beyond those deadlines. Id. at 284-85. Neither J.R. nor T.T. examined whether good cause existed for continuing the hearing beyond the statutory deadline.
Further, we agree with the Court of Appeals that relief is not available to Mother, who affirmatively waived the 180-day statutory timeframe and thus invited any alleged error. The invited-error doctrine is based on the doctrine of estoppel and forbids a party from taking advantage of an error that she commits, invites, or which is the natural consequence of her own neglect or misconduct. Durden v. State, 99 N.E.3d 645, 651 (Ind. 2018). Where a party invites the error, she cannot take advantage of that error. Witte v. Mundy ex rel. Mundy, 820 N.E.2d 128, 134 (Ind. 2005). In short, invited error is not reversible error. Booher v. State, 773 N.E.2d 814, 822 (Ind. 2002); C.T. v. Marion Cty. Dep’t of Child Servs., 896 N.E.2d 571, 588 (Ind. Ct. App. 2008), trans. denied.
Mother acknowledges she “affirmatively waived the 180-day requirement[.]” Trans. Pet. at 7. Having affirmatively waived that requirement and invited the court to conduct the hearing without regard to it, Mother cannot later successfully invoke it as a basis for reversal. Accord In re N.C., 83 N.E.3d 1265, 1267 (Ind. Ct. App. 2017) (finding a parent in a TPR case could be afforded no relief on appeal where, when the hearing was being scheduled, the court reporter proposed a hearing date 222 days after the petition’s filing and the parent’s counsel responded, “That sounds good.”), trans. not sought. Mother contends that “to allow the parties to agree to dates beyond the maximum 180-day limit would thwart the goals of timely permanency for children in the best possible environment, judicial economy, parents’ constitutional rights, and closure for all parties.” Appellant’s Br. at 28. Yet Mother presents this argument only after having invited any error.
Conclusion
The judgment of the trial court is affirmed for the reasons stated above.
Rush, C.J., and David, Massa, Slaughter, and Goff, JJ., concur.