7 canonical passages across 5 cases, quoted by 109 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from In Re Involuntary Termination.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | In Re Involuntary Termination Anchor | green | “need not rule out all possibilities of change; rather, dcs need establish only that there is a reasonable probability that the parent's behavior will not change.” | 30 |
| 2 | In Re Termination of Relationship of DD | green | “parental rights may be terminated when the parents are unable or unwilling to meet their parental responsibilities.” | 27 |
| 3 | In Re Involuntary Termination | green | “only that there is a reasonable probability that the parent's behavior will not change.” | 18 |
| 4 | In Re Involuntary Termination | green | “dcs need not rule out all possibilities of change; rather, it need establish only that there is a reasonable probability that the parent's behavior will not change.” | 10 |
| 5 | In the Matter of the Term. of the Parent-Child Rel. of A.P. & Au.P. M.H. & T.P. v. The Indiana Dept. of Child Services | green | “a parent's historical inability to provide a suitable environment along with the parent's current inability to do the same supports a finding that termination of parental rights is in the best interests of the children.” | 8 |
| 6 | S.E. v. Indiana Department of Child Services | green | “need not wait until a child is irreversibly harmed before terminating the parent-child relationship.” | 8 |
| 7 | A.M. v. Indiana Department of Child Services | green | “a judgment is clearly erroneous if the findings do not support the trial court's conclusions or the conclusions do not support the judgment.” | 8 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.