Under Indiana Code section 31-37-19-6, a dispositional decree may, among other things: remove the child from the child’s home and place the child in another home . . . and award wardship to a person, other than the department
Juvenile
In re the Termination of the Parent-Child Relationship of A.W., No. 24A-JT-3052, __ N.E.3d __ (Ind. Ct. App., Dec. 8, 2025).
In a termination of parental rights case, parents’ due process rights were violated by the trial court’s failure to compel DCS to disclose the names and contact information of child’s foster parents because that information could have led to the discovery of admissible evidence.
In re E.K., No. 25A-JC-703, __ N.E.3d __ (Ind. Ct. App., Oct. 16, 2025).
The Court could not take judicial notice of substantive controversial facts and rely on those facts in orders issued by a court in a non-adversarial proceeding where many typical due process protections are not observed.
In re P.F., No. 25A-JC-10, __ N.E.3d __ (Ind. Ct. App., Aug. 25, 2025).
Trial court erred in finding that reasonable efforts were not required to reunify child with parents; there was insufficient evidence that all the elements of the Multiple CHINS provision (Ind. Code 31-34-21-5.6(b)(7)) were proven. “Removed from the home of the child’s parent…under a dispositional decree” necessarily means that the child was placed outside the parent’s home for any period of time pursuant to a dispositional decree. A trial home visit at a parent’s house is not “removal.”
D.W. v. State, No. 25S-JV-190, __ N.E.3d __ (Ind., Jul. 23, 2025).
A juvenile court has a mandatory obligation to offer a formal advisement of rights under the Advisement Statute – Ind. Code 31-37-12-5. In addition, a waiver of a juvenile’s constitutional, statutory, or otherwise afforded rights must be done through personal interrogation of the juvenile, by the court, to ensure the waiver was knowing and voluntary.