Indiana Code

Ind. Code § 29-3-2-3 (2026)

Guardian ad litem; appointment

✓ current as of May 2026
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     Sec. 3. (a) Unless waived under subsection (b) or if section 4 of this chapter does not apply, the court shall appoint a guardian ad litem to represent the interests of the alleged incapacitated person or minor if the court determines that the alleged incapacitated person or minor is not represented or is not adequately represented by counsel. If not precluded by a conflict of interest, a guardian ad litem may be appointed to represent several persons or interests. The court as part of the record of the proceeding shall set out its reasons for appointing a guardian ad litem.

     (b) If a minor has or is entitled to property for the preservation of which the appointment of a guardian is necessary, and the court makes written findings that:

(1) the proposed guardian is capable of representing and managing the minor's property;

(2) no other petition for the appointment of a guardian has been filed; and

(3) the petition for the appointment of the proposed guardian is uncontested;

the court may waive the appointment of a guardian ad litem for the minor.

As added by P.L.169-1988, SEC.1. Amended by P.L.33-1989, SEC.63; P.L.154-1990, SEC.12; P.L.118-1997, SEC.25.

 

Notes of Decisions
Cited in 12 cases, 1997–2018 · leading case: In Re Paternity of MGS, 756 N.E.2d 990 (Ind. Ct. App. 2001).
In Re Paternity of MGS, 756 N.E.2d 990 (Ind. Ct. App. 2001). · cites it 2× “Under Indiana Code section 29-3-2-3(a), the court must appoint a guardian ad litem to represent the interests of a minor "if the court determines that the .”
Parks v. Delaware Cnty. Dep't of Child Servs., 862 N.E.2d 1275 (Ind. Ct. App. 2007). · cites it 2× “Code § 31-17-5-6 (providing that ''[u]pon hearing evidence in support of and opposition to a petition [for grandparent visitation], the court shall enter a *1279 decree setting forth the court’s findings and conclusions”), and appointments of a guardian ad litem, see Ind. Code §…”
In Re Adoption of BCS, 793 N.E.2d 1054 (Ind. Ct. App. 2003). · cites it 4× “According to the Gerwecks, both Ind.Code § 29-3-2-3 6 and Ind. Trial Rule 17(C) 7 required the trial court to appoint a guardian ad litem.”
In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009). · cites it 2× “pursuant to Indiana Code Section 29-3-2-3. Father attached the joint paternity affidavit as an exhibit.”
Chavis v. Patton, 683 N.E.2d 253 (Ind. Ct. App. 1997). · cites it 2× “See I.C. §§ 29-3-2-3, 29-3-9-7. As such, the trial court acted pursuant to the guardianship statute.”
In Re Guardianship of Hickman, 811 N.E.2d 843 (Ind. Ct. App. 2004). “§ 29-3-2-3. This section does not require that the guardian ad litem also petition for the appointment of a permanent guardian, as Joseph did.”
Wachowski v. Beke, 756 N.E.2d 990 (Ind. Ct. App. 2001). · cites it 2× “Under Indiana Code section 29-3-2-3(a), the court must appoint a guardian ad litem to represent the interests of a minor "if the court determines that the .”
In Re The Guardianship of Samantha R. Barton, Harriet Barton v. James P. Barton (mem. dec.) (Ind. Ct. App. 2015). · cites it 6× “Ind. Code § 29-3-2-3 (a). [29] On June 12, 2013, Father filed a verified motion for appointment of a guardian ad litem “to represent the interests of Samantha [] in this matter.”
Richard Frye v. Sarah (Frye) Mosby (mem. dec.) (Ind. Ct. App. 2018). · cites it 2× “” Indiana Code section 29-3-2-3 uses the language similar to Trial Rule 17(C), providing, in pertinent part, that (a) Unless waived under subsection (b) or if section 4 of this chapter does not apply, the court shall appoint a guardian [ad litem] to represent the interests of…”
In Re The Guardianship of J.M.: Christina M. Martin (Kibalko) v. William P. Hitch & Georgia L. Hitch (Ind. Ct. App. 2013). · cites it 2× “Indiana Code Section 29-3-2-3(a) provides that “the court shall appoint a 6 Because we conclude that the Guardians have met their burden to prove by clear and convincing evidence that J.”
Michael Ramos v. Robertson's Apts. (Ind. Ct. App. 2012). · cites it 2× “For example, Indiana Code Section 29-3-2-3 uses language similar to Trial Rule 17(C), providing that “the court shall appoint a guardian ad litem to represent the interests of the alleged incapacitated person or minor if the court determines that the alleged incapacitated person…”
In Re Support of J.D. T.F. v. J.J.D. (mem. dec.) (Ind. Ct. App. 2015). · cites it 2× “, I.C. § 29-3-2-3 (requiring appointment of a GAL in certain guardianship proceedings), whether to Court of Appeals of Indiana | Memorandum Decision 37A03-1507-JP-906 | November 30, 2015 Page 5 of 8 appoint a GAL is ordinarily a matter our statutes “leave to the juvenile court’s…”
Ind. Code § 29-3-2-3(a): 4 cases
In Re Paternity of MGS, 756 N.E.2d 990 (Ind. Ct. App. 2001). “Under Indiana Code section 29-3-2-3(a), the court must appoint a guardian ad litem to represent the interests of a minor "if the court determines that the .”
Wachowski v. Beke, 756 N.E.2d 990 (Ind. Ct. App. 2001). “Under Indiana Code section 29-3-2-3(a), the court must appoint a guardian ad litem to represent the interests of a minor "if the court determines that the .”
In Re The Guardianship of J.M.: Christina M. Martin (Kibalko) v. William P. Hitch & Georgia L. Hitch (Ind. Ct. App. 2013). “Indiana Code Section 29-3-2-3(a) provides that “the court shall appoint a 6 Because we conclude that the Guardians have met their burden to prove by clear and convincing evidence that J.”
In Re The Guardianship of Samantha R. Barton, Harriet Barton v. James P. Barton (mem. dec.) (Ind. Ct. App. 2015). “Ind. Code § 29-3-2-3 (a). [29] On June 12, 2013, Father filed a verified motion for appointment of a guardian ad litem “to represent the interests of Samantha [] in this matter.”
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