Indiana Code

Ind. Code § 29-3-5-4 (2026)

Considerations for appointment of guardian

✓ current as of May 2026
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     Sec. 4. (a) The court shall appoint as guardian a qualified person or persons most suitable and willing to serve, having due regard to the following:

(1) Any request made by a person alleged to be an incapacitated person, including designations in a durable power of attorney under IC 30-5-3-4(a).

(2) Any request made for a minor by:

(A) a parent of the minor; or

(B) a de facto custodian of the minor, including a designation in a power of attorney under IC 30-5-3-4(b) or IC 30-5-3-4(c).

(3) Any request contained in a will or other written instrument.

(4) A designation of a standby guardian under IC 29-3-3-7.

(5) Any request made by a minor who is at least fourteen (14) years of age.

(6) Any request made by the spouse of the alleged incapacitated person.

(7) The relationship of the proposed guardian to the individual for whom guardianship is sought.

(8) Any person acting for the incapacitated person under a durable power of attorney.

(9) The best interest of the incapacitated person or minor and the property of the incapacitated person or minor.

     (b) In addition to subsection (a), section 4.1 of this chapter applies when a prospective guardian is a person with a disability.

As added by P.L.169-1988, SEC.1. Amended by P.L.264-1989, SEC.7; P.L.149-1991, SEC.3; P.L.190-2016, SEC.39; P.L.194-2017, SEC.7; P.L.146-2021, SEC.1.

 

Notes of Decisions
Cited in 21 cases, 1999–2020 · leading case: In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009).
In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009). · cites it 18× “'s] co-guardians" under Indiana Code Sections 29-3-5-4 and -5. Appellants' Brief at 22.”
Cook v. Harris, 852 N.E.2d 933 (Ind. Ct. App. 2006). · cites it 8× “Code § 30-5-3-4(a); see also Ind.Code §§ 29-3-5-4; 29-3-5-5. Therefore, we remand with instructions to: (1) have the Estate Guardians file an accounting and inventory for Hollenga's estate; (2) remove the Estate Guardians as guardians over Hollenga's estate; and (3) appoint Cook…”
In re the Guardianship of Hellen Kinney Morris: Mary M. Kinney & Patrick Kinney v. Paul Kevin Kinney, 56 N.E.3d 719 (Ind. Ct. App. 2016). · cites it 2× “” Ind. Code § 29-3-5-4 ; see also Ind.Code § 29-3-5-5 (listing people entitled to consideration for appointment as guardian and the order of consideration).”
E.N. Ex Rel. Nesbitt v. Rising Sun-Ohio Cnty. Cmty. Sch. Corp., 720 N.E.2d 447 (Ind. Ct. App. 1999). · cites it 2× “Ind.Code § 29-3-5-4(7). Accordingly, the trial court properly included the best interest standard in determining whether to appoint a guardian for E.”
Ault v. Brewer, 922 N.E.2d 82 (Ind. Ct. App. 2010). · cites it 2× “Therefore, Toby made no nomination in a power of attorney that would make applicable the considerations of Indiana Code section 30-5-8-4, or the priorities favoring attorneys-in-fact in Indiana Code section 29-3-5-4 and 5. Appellants also contend that there was no evidence or…”
D.R. v. Carey Servs., Inc., 942 N.E.2d 148 (Ind. Ct. App. 2011). · cites it 10× “I.C. § 29-3-5-4 (emphasis added). The statutes also set forth a priority listing for individuals who may be considered for appointment as a guardian, but a court may disregard any individual with priority if such is in the best interests of the protected person.”
In re the Guardianship of: A.S.S. Glen Scisney v. Saleem Adams & Tamara Adams (mem. dec.) (Ind. Ct. App. 2018). · cites it 8× “[6] The Adamses maintain that the trial court did not err in naming them as the guardians of Child and correctly determined they were suitable persons to be appointed under Ind. Code § 29-3-5-4 (2). They argue the court was not required to enter special findings and that the…”
In re the Guardianship of: A.E.S. Glen Scisney v. Saleem Adams & Tamara Adams (mem. dec.) (Ind. Ct. App. 2018). · cites it 8× “The Adamses maintain that the trial court did not err in naming them as the guardians of Child under Ind. Code § 29-3-5-4 , that the GAL’s report admitted into evidence contained the power of attorney executed by Mother and Connor, and that Scisney’s argument is a request to…”
In the Matter of the Guardianship of Shirla Gonzalez Xitumul: Miguel Hernandez Jeronimo (Ind. Ct. App. 2019). · cites it 6× “]” Ind. Code § 29-3-5-4 (emphasis added). The only restrictions on who may be appointed to serve as a guardian based upon the Court of Appeals of Indiana | Opinion 19A-GU-948 | November 20, 2019 Page 11 of 17 status of that person are found in Indiana Code section 29-3-7-7, and…”
In re the Guardianship of Benjamin Jack, an Incapacitated Person, Alex Jack (Father) v. Christine Jack (Mother) (mem. dec.) (Ind. Ct. App. 2020). · cites it 6× “Mother argues Father waived his argument regarding a sole guardian, Ind. Code § 29-3-5-4 provides the court may appoint persons as co-guardians, and the court heard evidence supporting its conclusion that she should be named as co-guardian.”
In Re Guardianship of JY, 942 N.E.2d 148 (Ind. Ct. App. 2011). · cites it 10× “I.C. § 29-3-5-4 (emphasis added). The statutes also set forth a priority listing for individuals who may be considered for appointment as a guardian, but a court may disregard any individual with priority if such is in the best interests of the protected person.”
The Guardianship of J.H., D.H., & R.H., W.B. & S.B. v. J.A. & H.A. (mem. dec.) (Ind. Ct. App. 2019). · cites it 3× “Ind. Code § 29-3-5-4 (2)(A). Court of Appeals of Indiana | Memorandum Decision 19A-GU-406 | July 30, 2019 Page 7 of 7”
— Ind. Code § 29-3-5-4(2) — 1 case
In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009). “'s] co-guardians" under Indiana Code Sections 29-3-5-4 and -5. Appellants' Brief at 22.”
— Ind. Code § 29-3-5-4(5) — 1 case
In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009). “'s] co-guardians" under Indiana Code Sections 29-3-5-4 and -5. Appellants' Brief at 22.”
— Ind. Code § 29-3-5-4(7) — 3 cases
In Re the Guardianship of A.L.C., 902 N.E.2d 343 (Ind. Ct. App. 2009). “'s] co-guardians" under Indiana Code Sections 29-3-5-4 and -5. Appellants' Brief at 22.”
E.N. Ex Rel. Nesbitt v. Rising Sun-Ohio Cnty. Cmty. Sch. Corp., 720 N.E.2d 447 (Ind. Ct. App. 1999). “Ind.Code § 29-3-5-4(7). Accordingly, the trial court properly included the best interest standard in determining whether to appoint a guardian for E.”
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