Indiana Code

Ind. Code § 31-19-9-15 (2026)

When consent of putative father irrevocably implied; additional circumstances

✓ current as of May 2026
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     Sec. 15. (a) The putative father's consent to adoption of the child is irrevocably implied without further court action if the father:

(1) fails to file a paternity action:

(A) under IC 31-14; or

(B) in a court located in another state that is competent to obtain jurisdiction over the paternity action;

not more than fifteen (15) days after receiving actual notice under IC 31-19-3 of the mother's intent to proceed with an adoptive placement of the child, regardless of whether the child is born before or after the expiration of the fifteen (15) day period; or

(2) files a paternity action:

(A) under IC 31-14; or

(B) in a court located in another state that is competent to obtain jurisdiction over the paternity action;

during the fifteen (15) day period prescribed by subdivision (1) and fails to establish paternity in the paternity proceeding under IC 31-14 or the laws applicable to a court of another state when the court obtains jurisdiction over the paternity action.

     (b) This section does not prohibit a putative father who meets the requirements of section 17(b) of this chapter from establishing paternity of the child.

[Pre-1997 Recodification Citation: 31-3-1-6.4(d).]

As added by P.L.1-1997, SEC.11. Amended by P.L.200-1999, SEC.21; P.L.89-2023, SEC.6.

 

Notes of Decisions
Cited in 14 cases, 1998–2020 · 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 28× “The trial court also found that Wachowski had failed to file his paternity action within thirty days of receiving notice of the adoption and, therefore, his consent to adoption was irrevocably implied pursuant to I.”
In Re Paternity of Baby W, 774 N.E.2d 570 (Ind. Ct. App. 2002). · cites it 26× “Whether Indiana Code section 31-19-9-15 is a "nonclaim" statute that is not subject to equitable exceptions; 3.”
Walker v. Campbell, 711 N.E.2d 42 (Ind. Ct. App. 1999). · cites it 13× “Additionally, Indiana Code § 31-19-9-15 prescribes a procedure under which a putative father whose parental rights have not otherwise been extinguished, must file a paternity action to establish his paternity within thirty (30) days after receiving notice of the mother's…”
In Re Adoption of Baby W., 796 N.E.2d 364 (Ind. Ct. App. 2003). · cites it 5× “The Paternity Appeal Sharp appealed the trial court's dismissal of his paternity action, in part, on grounds that: (1) the pre-birth adoption notice that he received from the Adoptive Parents did not substantially comply with the requirements of Indiana Code Section 31-19-9-15;…”
Covington v. Marion Cnty. Off. of Fam. & Child., 840 N.E.2d 865 (Ind. Ct. App. 2006). · cites it 8× “See also Ind.Code § 31-19-9-15(a). [3] In asking this Court to apply this statutory *871 language, which deals directly with the rights of a putative father to contest adoption proceedings, to the case before us, which deals with a putative father's challenge to the termination…”
Mathews v. Hansen, 797 N.E.2d 1168 (Ind. Ct. App. 2003). · cites it 4× “IC. § 31-19-9-15. Moreover, such consent is implied regardless of whether the child is born before or after the expiration of the thirty-day time period.”
Sharp v. Fields, 774 N.E.2d 570 (Ind. Ct. App. 2002). · cites it 24× “Whether Indiana Code section 31-19-9-15 is a “nonclaim” statute that is not subject to equitable exceptions; 3.”
Wachowski v. Beke, 756 N.E.2d 990 (Ind. Ct. App. 2001). · cites it 19× “The trial court also found that Wachowski had failed to file his paternity action within thirty days of receiving notice of the adoption and, therefore, his consent to adoption was irrevocably implied pursuant to I.C. § 31-19-9-15. App. at 14. Accordingly, the trial court found…”
Matter of Adoption of MAS, 695 N.E.2d 1037 (Ind. Ct. App. 1998). · cites it 2× “4 (repealed 1997, current version at I.C. § 31-19-9-15) ] of this chapter...." I.”
Sharp v. Fields, 796 N.E.2d 364 (Ind. Ct. App. 2003). · cites it 6× “See also Ind.Code § 31-19-9-15. . In the Paternity Appeal, we observed that Sharp's May 21 Letter demonstrated no intent to take responsibility for Baby W in the event that testing confirmed that he was the father.”
Parks v. Jarboe, 695 N.E.2d 1037 (Ind. Ct. App. 1998). · cites it 2× “4 (repealed 1997, current version at I.C. § 31-19-9-15) ] of this chapter-” I.”
In the Adoption of K.H., D.R. v. M.M. & C.M. (Ind. Ct. App. 2020). · cites it 4× “’s consent was not required because he had only made token efforts with the child, he failed to file a paternity action and his consent is not required under Ind. Code § 31-19-9-15 , he failed to register with the putative father registry, he was unfit to parent, and adoption…”
Ind. Code § 31-19-9-15(2): 2 cases
In Re Paternity of MGS, 756 N.E.2d 990 (Ind. Ct. App. 2001). “The trial court also found that Wachowski had failed to file his paternity action within thirty days of receiving notice of the adoption and, therefore, his consent to adoption was irrevocably implied pursuant to I.”
Wachowski v. Beke, 756 N.E.2d 990 (Ind. Ct. App. 2001). “The trial court also found that Wachowski had failed to file his paternity action within thirty days of receiving notice of the adoption and, therefore, his consent to adoption was irrevocably implied pursuant to I.C. § 31-19-9-15. App. at 14. Accordingly, the trial court found…”
Ind. Code § 31-19-9-15(a): 3 cases
Covington v. Marion Cnty. Off. of Fam. & Child., 840 N.E.2d 865 (Ind. Ct. App. 2006). “See also Ind.Code § 31-19-9-15(a). [3] In asking this Court to apply this statutory *871 language, which deals directly with the rights of a putative father to contest adoption proceedings, to the case before us, which deals with a putative father's challenge to the termination…”
In Re Paternity of Baby W, 774 N.E.2d 570 (Ind. Ct. App. 2002). “Whether Indiana Code section 31-19-9-15 is a "nonclaim" statute that is not subject to equitable exceptions; 3.”
Sharp v. Fields, 774 N.E.2d 570 (Ind. Ct. App. 2002). “Whether Indiana Code section 31-19-9-15 is a “nonclaim” statute that is not subject to equitable exceptions; 3.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.