Ind. Code » Title 31
Indiana Code

Ind. Code § 31-32-4-1 (2026)

Persons entitled to representation by counsel

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaInd. Code CornellLII Search CasesGoogle Scholar

     Sec. 1. The following persons are entitled to be represented by counsel:

(1) A child charged with a delinquent act, as provided by IC 31-32-2-2.

(2) A parent, in a proceeding to terminate the parent-child relationship, as provided by IC 31-32-2-5.

(3) Any other person designated by law.

[Pre-1997 Recodification Citations: 31-6-3-1(b) part; 31-6-3-2(c) part; part New.]

As added by P.L.1-1997, SEC.15.

 

Notes of Decisions
Cited in 26 cases (2 in the last 5 years), 2002–2026 · leading case: Baker v. Marion Cnty. Off. of Fam. & Child., 810 N.E.2d 1035 (Ind. 2004).
Sort: Relevance Newest Treatment
Baker v. Marion Cnty. Off. of Fam. & Child., 810 N.E.2d 1035 (Ind. 2004). · cites it 4× “Ind.Code Ann. §§ 31-32-4-1 and 31-32-2-5 (West 1998).”
J.A. v. Indiana Dep't of Child Servs., 4 N.E.3d 1158 (Ind. 2014). · cites it 4× “And Indiana Code section 31-32-4-1 likewise includes, among its list of persons entitled to counsel, “[a]ny other person designated by law.”
Lang v. Starke Cnty. Off. of Fam. & Child., 861 N.E.2d 366 (Ind. Ct. App. 2007). · cites it 2× “Ind.Code §§ 31-32-4-1; 31-32-2-5. However, the inquiry into whether counsel’s assistance was effective is not the Strickland 5 inquiry used in criminal cases; instead “the focus of the inquiry [is] whether it appears that the parents received a fundamentally fair trial whose…”
K.S. v. Marion Cnty. Dep't of Child Servs., 917 N.E.2d 158 (Ind. Ct. App. 2009). · cites it 3× “Code § 31-32-2-5 ; see also I.C. § 31-32-4-1. [5] It is not disputed in this appeal that Mother's trial counsel properly informed the court of Mother's last known address.”
S. R. v. M. J., 71 N.E.3d 436 (Ind. Ct. App. 2017). · cites it 2× “Furthermore, Indiana Code section 31-32-4-1(2) states that “[a] parent, in a proceeding to terminate the parent-child relationship” is “entitled to be represented by counsel.”
In Re Adoption of GWB, 776 N.E.2d 952 (Ind. Ct. App. 2002). · cites it 2× “" In addition, Ind.Code § 31-32-4-1 provides: "The following persons are entitled to be represented by counsel: .”
Lanny B. v. Marion Cnty. Dep't of Child Servs., 889 N.E.2d 326 (Ind. Ct. App. 2008). · cites it 2× “at 1039 ; see also Ind.Code Ann. § 31-32-4-1 (West, PREMISE through 2007 1st Regular Sess.”
In the Matter of the Involuntary Termination of the Parent-Child Relationship of G.P., & J.A. v. The Indiana Dep't of Child Servs., 985 N.E.2d 786 (Ind. Ct. App. 2013). · cites it 2× “Parents are entitled to representation in termination proceedings, Indiana Code section 31-32-4-1, and counsel may be appointed in other proceedings, Indiana Code section 31-32-4-3 (emphasis added).”
In the Termination of the Parent-Child Relationship of: X.S. (Minor Child), & S.S. (Father) v. The Indiana Dep't of Child Servs., & Lake Cnty. Court Appointed Special Advocate (mem. dec.), 117 N.E.3d 601 (Ind. Ct. App. 2018). · cites it 2× “Ind. Code §§ 31-32-4-1 and 31-32-2-5. Indiana Code "[s]ection 31-34-4-6 is an explicit provision of just such a statutory right, though subject to its own internal qualifications, and is consistent with the operation of the rest of the statutory scheme.”
Brooks v. McGee, 776 N.E.2d 952 (Ind. Ct. App. 2002). · cites it 2× “” In addition, Ind.Code § 31-32-4-1 provides: “The following persons are entitled to be represented by counsel: .”
In Re Lb, 889 N.E.2d 326 (Ind. Ct. App. 2008). · cites it 2× “at 1039 ; see also Ind.Code Ann. § 31-32-4-1 (West, PREMISE through 2007 1st Regular Sess.”
In Re the Adoption of K.W.: M.W. v. S.L. & T.L., 21 N.E.3d 96 (Ind. Ct. App. 2014). · cites it 2× “It noted: Reading the juvenile statutes collectively, Section 31-32-4-1 provides that parents in TPR proceedings are entitled to be represented by counsel, along with “[a]ny other person designated by law.”
Show all 26 citing cases →
Ind. Code § 31-32-4-1(2): 2 cases
S. R. v. M. J., 71 N.E.3d 436 (Ind. Ct. App. 2017). “Furthermore, Indiana Code section 31-32-4-1(2) states that “[a] parent, in a proceeding to terminate the parent-child relationship” is “entitled to be represented by counsel.”
In the Termination of the Parent-Child Relationship of: Ta.B., J.B., & Ty.B. (Minor Child.) & C.B. (Mother) & J.B., Sr. (Father) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2020).
Ind. Code § 31-32-4-1(3): 1 case
J.A. v. Indiana Dep't of Child Servs., 4 N.E.3d 1158 (Ind. 2014). “And Indiana Code section 31-32-4-1 likewise includes, among its list of persons entitled to counsel, “[a]ny other person designated by law.”
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.