Indiana Code
Ind. Code § 31-19-14-2 (2026)
Time for challenge to adoption decree
✓ current as of May 2026
Sec. 2. Except as provided in section 3 of this chapter, if a person whose parental rights are terminated by the entry of an adoption decree challenges the adoption decree not more than the later of:
(1) six (6) months after the entry of an adoption decree; or
(2) one (1) year after the adoptive parents obtain custody of the child;
the court shall sustain the adoption decree unless the person challenging the adoption decree establishes, by clear and convincing evidence, that modifying or setting aside the adoption decree is in the child's best interests.
[Pre-1997 Recodification Citation: 31-3-1.3-2(a).]
As added by P.L.1-1997, SEC.11.
Notes of Decisions
Cited in 9
cases (1 in the last 5 years), 2003–2023 · leading case: Mathews v. Hansen, 797 N.E.2d 1168 (Ind. Ct. App. 2003).
Mathews v. Hansen, 797 N.E.2d 1168 (Ind. Ct. App. 2003). “We begin our discussion by turning to Indiana Code section 31-19-14-2, the statute that prescribes the time for challenging an adoption decree: Except as provided in section 3 of this chapter, if a person whose parental rights are terminated by the entry of an adoption decree…”
Adoption of D.C. v. R.C., 887 N.E.2d 950 (Ind. Ct. App. 2008). “Analysis Indiana Code section 31-19-14-2 (2006) specifies the permissible time period for challenging adoption decrees: Except as provided in section 3 of this chapter, if a person whose parental rights are terminated by the entry of an adoption decree challenges the adoption…”
In the Matter of the Adoption of Minor Child.: C.B.M. & C.R.M.: C.A.B. v. J.D.M. & K.L.M., 979 N.E.2d 174 (Ind. Ct. App. 2012). “I.C. § 31-19-14-2 (emphasis added). Where a petitioner establishes or statute provides that notice of an adoption proceeding is not required, the petitioner need not obtain consent to the adoption from the parties who would otherwise be entitled to notice of the proceedings.”
In Re the Adoption of: N.I.D. (Minor Child), & C.C. (Mother) v. R.P. & K.P. (Ind. Ct. App. 2020). “” I.C. § 31-19-14-2. On appeal, R.P. and K.”
J.F. v. L.K. & G.K. (Ind. Ct. App. 2019). “’s motion for relief from judgment citing Ind. Code §§ 31-19-14-2 and -4. On January 31, 2019, the court held a hearing.”
In Re Adoption of DC, 887 N.E.2d 950 (Ind. Ct. App. 2008). “Analysis Indiana Code section 31-19-14-2 (2006) specifies the permissible time period for challenging adoption decrees: Except as provided in section 3 of this chapter, if a person whose parental rights are terminated by the entry of an adoption decree challenges the adoption…”
S P v. G F (Ind. Ct. App. 2023). “I.C. § 31-19-14-2. Grandfather’s challenge to the adoption decree, nearly three years after it was entered, was far too late.”
In the Matter of the Adoption of J.W. T. McD. v. G.C. (Ind. Ct. App. 2012). “Indiana Code section 31-19-14-2 (2010), the statute that prescribes the time for challenging an adoption decree provides as follows: Except as provided in section 3 of this chapter, if a person whose parental rights are terminated by the entry of an adoption decree challenges…”
In Re The Adoption of K.T. J.T. v. A.A.B. (Ind. Ct. App. 2013). “I.C. § 31-19-14-2 (West, Westlaw current with all 2013 legislation) provides for the challenge of an adoption decree within a certain timeframe if a person’s parental rights are terminated by the entry of the adoption decree.”
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