Rush, C.J.
Responding to the COVID-19 pandemic, this Court issued an order in May 2020—later extended through 2022—that amended Indiana Administrative Rule 14 to expand trial courts’ ability to conduct remote proceedings through audiovisual communication, often called “remote” or “virtual” hearings. Central to this case is the court’s burden under Rule 14 to find good cause for proceeding remotely when a party objects. We conclude that good cause requires particularized and specific factual support. Here, the trial court’s bare mention of “the COVID-19 pandemic” failed to meet that standard when it conducted a party’s commitment hearing virtually over her timely objection. But because we ultimately conclude that the error was harmless, we affirm.
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Indiana Administrative Rule 14 explains when and how trial courts may conduct remote proceedings using telephone or audiovisual telecommunication. On May 13, 2020, in recognition of the ongoing statewide COVID-19 emergency, this Court issued an order modifying Rule 14 to afford trial courts “broader authority to conduct court business remotely.” In re Admin. Rule 17 Emergency Relief for Ind. Trial Cts. Relating to the 2019 Novel Coronavirus, 144 N.E.3d 197, 197 (Ind. 2020). Specifically, the order—later extended through 2022—authorizes courts to use “audiovisual communication to conduct proceedings whenever possible to ensure all matters proceed expeditiously and fairly under the circumstances.” Id.
This authority, however, is not absolute. On a party’s objection “at the outset of the proceeding, on the record,” the trial court “must make findings of good cause to conduct the remote proceeding.” Id. at 198. Though modified Rule 14 will be replaced by Interim Rule 14 on January 1, 2023, the interim rule similarly requires “good cause shown” to conduct testimonial proceedings—such as commitment hearings—virtually. Interim Admin. Rule 14 for Remote Proc., 22S-MS-1 (Ind. Sept. 30, 2022).
Here, B.N. argues that the trial court failed to make the requisite findings of good cause to proceed remotely, entitling her to reversal of her commitment order and to an in-person hearing. Eskenazi counters that the trial court satisfied modified Rule 14 and that even if the court erred, any error was harmless. [Footnote omitted.] We hold that the trial court abused its discretion by proceeding with the virtual hearing without articulating any particular and specific facts supporting its decision—referring solely to COVID-19 is not enough. But, on this record, we hold that the error was harmless.
I. The trial court did not make the requisite findings of good cause to conduct B.N.’s commitment hearing virtually.
B.N. argues that the trial court, by simply referring to the COVID-19 pandemic, failed to comply with modified Administrative Rule 14’s requirement that “the court must make findings of good cause to conduct the remote proceeding” over a party’s timely objection. In re Admin. Rule 17, 144 N.E.3d at 198. Eskenazi disagrees, asserting that referring to “the national health crisis was sufficient good cause.” We agree with B.N.
Though this is our first opportunity to articulate what constitutes “findings of good cause” for purposes of modified Rule 14, the good-cause metric is utilized to assess the propriety of a trial court’s determination in various contexts. And, consistently, good cause requires a “particular and specific demonstration of fact.” Ramirez v. State, 186 N.E.3d 89, 95 (Ind. 2022) (quoting Ledden v. Kuzma, 858 N.E.2d 186, 192 (Ind. Ct. App. 2006)); see also, e.g., Campbell, 161 N.E.3d at 377; In re F.S., 53 N.E.3d 582, 597 (Ind. Ct. App. 2016); Stuff v. Simmons, 838 N.E.2d 1096, 1103–04 (Ind. Ct. App. 2005), trans. denied.
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We adopt the same good-cause standard for a trial court’s decision to conduct a remote proceeding under modified Administrative Rule 14 as well as the forthcoming Interim Rule 14. Findings of good cause under the modified rule or a showing of good cause under the interim rule require particularized and specific factual support.
Applying that standard here, recall that the court decided to proceed remotely “due to the COVID-19 pandemic.” But this generic reference does not amount to findings of good cause—especially when the pandemic was the impetus for modifying Rule 14. This is not to say that COVID-19-related concerns or constraints cannot satisfy the rule’s requisite findings. Indeed, in In re I.L., a trial court found good cause to hold a termination-of-parental-rights hearing remotely, citing several specific considerations: the pandemic was severe at that time, the courtroom would not allow for social distancing, and the litigants would still receive a full and fair hearing. 177 N.E.3d 864, 869 (Ind. Ct. App. 2021), adopted in part and summarily aff’d in part by 181 N.E.3d 974, 976 (Ind. 2022). By contrast, here, the only “finding” is the court’s general reference to the pandemic. Simply put, this record is devoid of any COVID-19- related concerns or constraints specific to the moment, the region, the courtroom, the parties, the type of proceeding, or any other circumstances that justified conducting the commitment hearing remotely over B.N.’s timely objection.
We emphasize that trial courts retain significant discretion to conduct remote proceedings over objection when there is good cause to do so. But they must offer something more than a one-size-fits-all, boilerplate pronouncement; good cause requires something specific to the moment, the case, the court, the parties, the subject matter, or other relevant considerations. To be sure, remote proceedings are here to stay and may be more efficient in various circumstances. But in-person evidentiary hearings are vital in certain proceedings, such as involuntary civil commitment hearings, where a party’s liberty interests are at stake. See A.A. v. Eskenazi Health/Midtown CMHC, 97 N.E.3d 606, 611 (Ind. 2018); cf. Warren v. State, 182 N.E.3d 925, 936 (Ind. Ct. App. 2022) (recognizing that a trial court can conduct a remote sentencing hearing under modified Rule 14 “only where a defendant waived his right to be physically present in the courtroom”). And thus, to proceed with a virtual hearing, good cause requires particularized and specific factual support.
Because the trial court did not satisfy this standard when it conducted B.N.’s commitment hearing remotely over her objection, the court abused its discretion. We now determine whether that error was harmless.
II. The trial court’s error was harmless.
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At the same time, we recognize that an involuntary civil commitment represents “a significant deprivation of liberty.” A.A., 97 N.E.3d at 611. And we also recognize that those facing civil commitment may be particularly sensitive to a virtual environment, where technological issues can arise that might acutely impact the individual. In-person commitment hearings should thus be the norm, not the exception. So, while we can certainly envision a scenario in which a trial court’s decision to proceed remotely in a commitment hearing without making the requisite findings of good cause results in reversible error, it does not here.
Conclusion
The trial court abused its discretion by failing to provide particularized and specific factual support to conduct B.N.’s commitment hearing remotely over her timely objection. But because we ultimately find that the error was harmless, we affirm.
Massa, Slaughter, Goff, and Molter, JJ., concur