Goff, J.
An adoption is a creature of paradox: it cements one relationship while it terminates another. To facilitate this shift, the legislature has provided the courts with standards by which to protect the rights of natural parents and the best interests of the children involved. Specifically, the natural parents must consent to the adoption. But in certain cases, such as this one, trial courts may, by statute, dispense with that consent requirement. Here, J.P., the biological mother (Mother), appealed the trial court’s finding that her consent was not required for the adoption of her child because, for a period of one year, she failed to communicate significantly with her child and failed to support her child when able and required to do so. Because we find that the trial court’s determinations were supported by sufficient evidence, we affirm its ruling.
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In this case, we confront the limited question of whether the trial court committed clear error when it determined that Mother failed for one year to (1) significantly communicate with Child without justification, or (2) support Child when able to do so and required by law. We find that ample evidence supports both determinations and that the trial court did not err in granting Stepmother’s petition for adoption.
I. Parental consent to adoption is usually, but not always, required.
A natural parent enjoys special protection in any adoption proceeding, and courts strictly construe our adoption statutes to preserve the fundamentally important parent-child relationship…
Three of these circumstances are at issue here: Consent from the natural parent is not required “if the child is adjudged to have been abandoned or deserted” for six months or more “immediately preceding the date of the filing of the petition for adoption,” or if, for at least one year, the parent “fails without justifiable cause to communicate significantly with the child when able to do so” or “knowingly fails to provide for the care and support of the child when able to do so as required by law or judicial decree.” I.C. §§ 31-19-9-8(a)(1)–(2).
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These cases reiterate a familiar theme. A parent who meets society’s expectations by maintaining a connection with her child and by financially supporting her child cannot have her legal relationship with the child severed without her consent. Conversely, when a parent fails to maintain a meaningful relationship with, or fails to financially support, that child, she loses her right as a natural parent to withhold consent to adoption. Of course, what constitutes failure is a fact-intensive inquiry. And so, we now turn our attention to the evidence here.
II. Sufficient evidence supports the trial court’s decision.
A. There was sufficient evidence that Mother failed to communicate significantly with Child without justifiable cause for at least one year.
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While Mother’s contact with Child was somewhat regular, the evidence supports the trial court’s conclusion that her communication wasn’t significant. We agree with Mother that phone contact “could be significant” communication. See Appellant’s Br. at 11. But Father testified that, during the year at issue, the phone communication between Mother and Child averaged thirteen minutes per month. 2 What’s more, Mother sent no letters to Child during the relevant year and never visited with her, as she was permitted to do under the custody order. Mother did, however, choose to exercise supervised parenting time with one of her other children. And as further evidence of her failure to communicate, Mother couldn’t name any of Child’s friends or even where she attended school. While Indiana courts have occasionally found that consent for adoption was required with less contact between a natural parent and child, those cases generally involved a parent whose active pursuit of, and success in, substance-abuse recovery justified their reduced communication with their child. See, e.g., In re Adoption of D.H., 135 N.E.3d 914, 924 (Ind. Ct. App. 2019); E.B.F., 93 N.E.3d at 765. While Mother did struggle with substance abuse, and while she argued that her troubles and efforts at recovery excused her lack of financial support, she advanced no such argument related to her lack of communication before either the trial court or the Court of Appeals. Instead, the evidence shows a paucity of conversations between Mother and Child and that Mother couldn’t provide basic information about Child’s life, such as who her friends were and where she attended school. Based on this evidence, and given our deferential standard of review, we cannot say that the trial court erred in its determination.
B. There was sufficient evidence that Mother failed to support Child when able and required to do so.
The trial court also found that Mother’s consent for adoption wasn’t required because she failed to financially support Child. Under the Consent-to-Adoption Statute, consent isn’t required when a parent “knowingly fails to provide for the care and support of the child when able to do so as required by law or judicial decree.” I.C. § 31-19-9- 8(a)(2)(B). When Father gained custody of Child, the court ordered Mother to pay $46.00 a week in child support. Mother never paid any child support. She argues that she was unable to hold “meaningful employment” because of her time in jail, her lack of transportation due to a driver’s license suspension, her efforts to regain custody of her other children, and her schooling. Appellant’s Br. at 6. And because she was unable to support Child, Mother insists that the trial court’s determination was erroneous.
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C. We need not address whether the trial court erred in finding that Mother abandoned Child.
Finally, Mother argues that the trial court erred in determining that she abandoned Child, citing to Indiana Code section 31-19-9-8(b), which provides that a parent abandons a child when she makes “only token efforts to support or communicate with the child.” This argument suggests that Mother’s attempt at communicating with Child amounted to something more than a “token” effort. But Mother fails to develop this argument. Abandonment is an independent ground for dispensing with the consent requirement. See I.C. § 31-19-9-8(a)(1) (Consent is not required from a “parent or parents if the child is adjudged to have been abandoned or deserted for at least six (6) months immediately preceding the date of the filing of the petition for adoption.”) In fact, all of Mother’s arguments revolve around the one-year timetable provided by the failure-to-communicate and failure-to-support subsections, not the six months of abandonment required to dispense with the consent requirement. When Stepmother argued before the Court of Appeals that Mother had waived the issue of abandonment, Mother simply responded that her arguments about failure to communicate and failure to support were applied to the abandonment issue as well. Appellant’s Reply Br. at 4. The Court notes that these issues seem to require separate analyses because the time period at issue is different. See I.C. §§ 31-19-9-8(a)(1), (a)(2). Mother didn’t engage in a separate analysis related to abandonment.
Because Mother’s argument that she hadn’t abandoned Child is arguably waived for failure to present a cogent argument, see United States Fid. & Guar. Ins. Co. v. Hartson-Kennedy Cabinet Top Co., 857 N.E.2d 1033, 1038 (Ind. Ct. App. 2006), and because other grounds support the trial court’s conclusion that Mother’s consent wasn’t required, we decline to address whether the trial court committed clear error when it determined that Mother abandoned Child.
Conclusion
Because the evidence supports the trial court’s findings that Mother for one year failed to significantly communicate with Child and support Child when able to do so, we affirm the trial court.
Rush, C.J., and David, Massa, and Slaughter, JJ., concur