Indiana Code

Ind. Code § 31-35-2-4 (2026)

Petition to terminate parent-child relationship; filing; required allegations

✓ current as of May 2026

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Sec. 4. (a) A petition to terminate the parent-child relationship involving a child adjudicated as a delinquent child or child in need of services may be signed and filed with the juvenile or probate court by any of the following:

(1) The attorney for the department.

(2) The child's court appointed special advocate.

(3) The child's guardian ad litem.

(4) An individual:

(A) with whom the child is placed during; and

(B) who is an intervenor in;

the child in need of services proceedings regarding the child as provided in section 3.5 of this chapter.

(b) A petition filed under subsection (a) must be entitled "In the Matter of the Termination of the Parent-Child Relationship of ___________, a child, and ____________, the child's parent (or parents)".

(1) the existence of one (1) or more of the circumstances described in subsection (d);

(2) that there is a satisfactory plan for care and treatment of the child; and

(3) that termination of the parent-child relationship is in the child's best interests.

(d) A petition filed under subsection (a) must allege the existence of one (1) or more of the following circumstances:

(1) That a court has entered a finding under IC 31-34-21-5.6 that reasonable efforts for family preservation or reunification are not required, including a description of the court's finding, the date of the finding, and the manner in which the finding was made.

(2) That:

(A) the child has been removed from the parent and has been under the supervision of a local office or probation department for at least fifteen (15) months of the most recent twenty-two (22) months, beginning with the date the child is removed from the home as a result of the child being alleged to be a child in need of services or a delinquent child; and

(B) despite the department's reasonable efforts to preserve and reunify the child's family under IC 31-34-21-5.5, the parent has been unable to remedy the circumstances that resulted in the child being placed in care outside the parent's home.

(3) That there is a reasonable probability that the conditions that resulted in the child's removal or the reasons for placement outside the home of the parents will not be remedied.

(4) That there is a reasonable probability that the continuation of the parent-child relationship poses a threat to the well-being, safety, physical health, or life of the child.

(5) That the child has, on two (2) separate occasions, been adjudicated a child in need of services.

(6) That:

(A) at least ninety (90) days have passed since the filing of the petition alleging that the child is a child in need of services; and

(B) the identity or location of the parent is unknown despite reasonable efforts having been made to identify or locate the parent.

(7) That the parent:

(A) failed to substantially comply with the child's dispositional decree for a period of at least twelve (12) months following the child's:

(i) removal from the parent's home under IC 31-34-2; or

(ii) adjudication as a child in need of services;

whichever occurred earlier, unless the parent's failure to substantially comply with the child's dispositional decree was due to the failure of the department to make reasonable efforts to preserve and reunify the child's family under IC 31-34-21-5.5; or

(B) is unlikely or unable to substantially comply with the child's dispositional decree.

(8) That the parent is incarcerated and one (1) or more of the following is true:

(A) The parent is expected to remain incarcerated for a significant portion of the remaining time during which the child is less than eighteen (18) years of age. When determining whether the portion of the remaining time is significant, the court shall consider the following factors:

(i) The age of the child.

(ii) The relationship between the child and the parent.

(iii) The nature of the parent's current and past provision for the child's developmental, cognitive, psychological, and physical needs.

(iv) The parent's history of criminal behavior, including the frequency of the parent's incarceration and the unavailability of the parent to the child due to the parent's incarceration.

(v) Any other factor the court considers relevant.

(B) The parent is a sexually violent predator (as defined by IC 35-38-1-7.5).

(9) That the parent:

(A) has a history of extensive, abusive, and chronic use of alcohol or a controlled substance that renders the parent incapable of caring for the child; and

(B) either:

(i) has refused or failed to complete available treatment for the alcohol or controlled substance use during the two (2) year period immediately preceding the filing date of the petition under subsection (a); or

(ii) has completed treatment for the alcohol or controlled substance use but has resumed use of alcohol or a controlled substance after being reunified with the child.

(10) That:

(A) a test administered at the child's birth that indicated that the child's blood, urine, umbilical cord tissue, or meconium contained any amount of alcohol or a controlled substance, or metabolites of such substances, the presence of which was not the result of medical treatment administered to the mother or the child; and

(B) the parent:

(i) is the biological mother of at least one (1) other child who was adjudicated a child in need of services after a finding of harm to the child's health or welfare due to exposure to alcohol or a controlled substance; and

(ii) had the opportunity to participate in substance abuse treatment following the finding under item (i).

(11) That the child was conceived as a result of:

(A) an offense under IC 35-42-3.5 (human and sexual trafficking);

(B) rape (IC 35-42-4-1);

(D) sexual misconduct with a minor (IC 35-42-4-9); or

(E) an offense committed in another jurisdiction the elements of which are substantially similar to the elements of an offense described in clause (A), (B), (C), or (D);

committed by the biological parent of the child whose parent-child relationship with the child is the subject of the petition.

(12) That the parent is required to register as a sex or violent offender under IC 11-8-8.

(13) That one (1) or more circumstances described in section 3.5 of this chapter have occurred.

(e) If the department intends to file a motion to dismiss under section 4.5 of this chapter, the petition must indicate whether at least one (1) of the factors listed in section 4.5(d)(1) through 4.5(d)(4) of this chapter applies and specify each factor that would apply as the basis for filing a motion to dismiss the petition.

[Pre-1997 Recodification Citation: 31-6-5-4(a), (c).]

As added by P.L.1-1997, SEC.18. Amended by P.L.35-1998, SEC.19; P.L.200-1999, SEC.29; P.L.146-2008, SEC.615; P.L.131-2009, SEC.65; P.L.21-2010, SEC.8; P.L.48-2012, SEC.66; P.L.42-2017, SEC.2; P.L.258-2019, SEC.3; P.L.70-2024, SEC.4; P.L.179-2025, SEC.25.

Notes of Decisions

Cited in 1,357 cases (10 in the last 5 years), 1997–2025 · leading case: Term. of Parent-Child Rel. of I.A. J.H. v. IDCS, 934 N.E.2d 1127 (Ind. 2010).

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Term. of Parent-Child Rel. of I.A. J.H. v. IDCS, 934 N.E.2d 1127 (Ind. 2010). · cites it 21× “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). The record shows that I.”

R.C. v. Indiana Dep't of Child Servs., 989 N.E.2d 1225 (Ind. 2013). · cites it 14× “2002)); I.C. § 31-35-2-4(b)(2). In this case the trial court determined that both allegations were satisfied.”

In the Matter of the Termination of the Parent-Child Relationship of E.M. & El.M., E.M. v. Indiana Dep't of Child Servs., 4 N.E.3d 636 (Ind. 2014). · cites it 8× “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). Where the State fails to prove “any one” of the statutory elements “it is not entitled to a judgment terminating parental rights.”

Involuntary Termination of Parent-Child Relationship of K.E. v. Indiana Dep't of Child Servs., 39 N.E.3d 641 (Ind. 2015). · cites it 12× “Conclusion Without clear and convincing evidence to support each of the factors set out in Indiana Code § 31-35-2-4(b), we cannot terminate a parent-child relationship.”

T.Q. v. Indiana Dep't of Child Servs., 996 N.E.2d 385 (Ind. Ct. App. 2013). · cites it 12× “The timing requirements provided by Ind. Code § 31-35-2-4 (b)(2)(A) are in place for a reason, namely, to insure that parents have an adequate opportunity to make the corrections necessary in order to keep their family unit intact.”

Termination: VG v. Indiana Dep't of Child Servs., 69 N.E.3d 464 (Ind. 2017). · cites it 14× “” Ind. Code § 31-35-2-4 (b)(2)(A)(i) (Supp.”

Termination: KC v. Indiana Dep't of Child Servs., 71 N.E.3d 898 (Ind. Ct. App. 2017). · cites it 14× “Ind. Code § 31-35-2-4 (b)(2). DCS must provide clear and convincing proof of these allegations.”

A.M. v. Indiana Dep't of Child Servs., 45 N.E.3d 471 (Ind. Ct. App. 2015). · cites it 13× “Ind,Code§ 31-35-2-4,5. . "[I]n the case of a child-who has been in foster care under the responsibility of the State for 15 of the most recent 22 months, .”

Bester v. Lake Cnty. Off. of Fam. & Child., 839 N.E.2d 143 (Ind. 2005). · cites it 4× “Indiana Code § 31-35-2-4(b)(@Q) requires that a petition to terminate a parent-child relationship involving a child in need of services must allege that: (A) one (1) of the following exists: (i) The child has been removed from the parent for at least six (6) months under a…”

McBride v. Monroe Cnty. Off. of Fam. & Child., 798 N.E.2d 185 (Ind. Ct. App. 2003). · cites it 4× “] Ind.Code § 31-35-2-4(b)(2)(B). The OFC must also show that termination is in the best interests of the child.”

In the Matter of the Term. of the Parent-Child Rel. of J.C., Et.C. & El.C. S.C. v. Indiana Dep't of Child Servs., 994 N.E.2d 278 (Ind. Ct. App. 2013). · cites it 6× “Pursuant to Ind.Code § 31-35-2-4(b)(1)(D), DCS must provide sufficient evidence there is a satisfactory plan for the care and treatment of the child.”

In Re Termination of Relationship of DD, 804 N.E.2d 258 (Ind. Ct. App. 2004). · cites it 6× “" Ind.Code § 31-35-2-4 (emphasis added). The trial court also found a reasonable probability that the reasons for continued placement outside of Mother's home would not be remedied, and this finding is not clearly erroneous.”

Show all 1,357 citing cases →

— Ind. Code § 31-35-2-4(2) — 1 case

Term. of the Parent-Child Rel. of K.S. & K.C. (Minor Child.) & Y.C. (Mother) v. The Indiana Dept. of Child Servs. (Ind. Ct. App. 2012).

— Ind. Code § 31-35-2-4(2)(A) — 1 case

In Re the Term. of the Parent-Child Rel. of: C v. O v. & J v. & G.J. v. The Indiana Dept. of Child Servs. (Ind. Ct. App. 2012).

— Ind. Code § 31-35-2-4(2)(A)(1) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of P.W., Father, & T.Y., Mother v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2016).

— Ind. Code § 31-35-2-4(2)(B) — 1 case

In re the Termination of the Parent-Child Relationship of B.B.K, J-E.K., J-M.K., & A-M.K. (Minor Child.) & M.K. (Mother) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2020).

— Ind. Code § 31-35-2-4(2)(B)(2) — 1 case

In Re the Involuntary Term. of the Parent-Child Relationship of: Au.R. & Ay.R. (Minor Child.) & R.W. (Mother) v. Ind. Dept. of Child Servs. (mem. dec.) (Ind. Ct. App. 2015).

— Ind. Code § 31-35-2-4(B) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of: Q.M. & E.M., Minor Child., B.M., Father v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2013).

— Ind. Code § 31-35-2-4(B)(2) — 5 cases

In Re the Matter of the Termination of the Parent-Child Relationship of R.P. S.P. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2019).

In the Matter of the Involuntary Termination of the Parent-Child Relationship of E.O. (Minor Child) T.G. (Mother) v. Indiana Dep't of Child Servs., & Child Advocates, Inc. (mem. dec.) (Ind. Ct. App. 2019).

In the Termination of the Parent-Child Relationship of S.M. (minor child) H.M. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2019).

In Re: The Matter of the Termination of the Parent-Child Relationship of A.B. (Minor Child) L.B. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2020).

In Re: The Matter of the Termination of the Parent-Child Relationship of R.S. (Minor Child) T.L. (Father) v. The Indiana Dep't of Child Servs. (Ind. Ct. App. 2020).

— Ind. Code § 31-35-2-4(B)(2)(B) — 2 cases

In re the Termination of the Parent-Child Relationship of S.K., E.K., & M.K. (Minor Child.), & S.K., Sr. (Father) v. Indiana Dep't of Child Servs., 124 N.E.3d 1225 (Ind. Ct. App. 2019).

In the Matter of the Termination of the Parent-Child Relationship of M.N. (Child) & S.N. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

— Ind. Code § 31-35-2-4(B)(2)(C) — 8 cases

In the Termination of the Parent-Child Relationship of: T.H. (Minor Child), & B.H. (Father) & D.A. (Mother) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

In the Matter of the Involuntary Termination of the Parent-Child Relationship of: N.R v. (Minor Child) & N.M v. (Mother) v. The Indiana Dep't of Child Servs. (mem.dec.) (Ind. Ct. App. 2018).

In the Matter of the Involuntary Termination of the Parent-Child Relationship of: M.S., Je.S., & Ja.S. (Minor Child.) & C.I. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

In Re the Matter of the Termination of the Parent-Child Relationship of: N.M., R.M., L.M. & T.M. (Minor Child.) & R.B. (Mother), R.M. (Father) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

In the Matter of the Involuntary Termination of the Parent-Child Relationship of: J.C. (Minor Child) & J.M.C. (Father) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

— Ind. Code § 31-35-2-4(B)(2)(a) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of: Q.M. & E.M., Minor Child., B.M., Father v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2013).

— Ind. Code § 31-35-2-4(C) — 1 case

In the Matter of the Term. of the Parent-Child Relationship of: N.G., L.C., & M.C. (Minor Child.), & A.C. & J.G. (Their Parents) A.C. (Mother) v. Ind. Dept. of Child Servs. (mem. dec.), 51 N.E.3d 1167 (Ind. 2016).

— Ind. Code § 31-35-2-4(a) — 7 cases

In the Matter of the Involuntary Termination of the Parent-Child Relationship of Z.B., D.B., L.B., Me.B., Ma.B. (Minor Child.) & A.B. (Mother) v. The Indiana Dep't of Child Servs., 108 N.E.3d 895 (Ind. Ct. App. 2018).

In the Termination of the Parent-Child Relationship of: R.L.-P. (Minor Child) & M.E. (Father) v. The Indiana Dep't of Child Servs., 119 N.E.3d 1098 (Ind. Ct. App. 2019).

In the Matter of the Involuntary Term. of the Parent-Child Relationship of A.B. (Minor Child): G.B. (Mother) & C.B. (Father) v. Ind. Dept. of Child Servs. (mem. dec.) (Ind. Ct. App. 2016).

In the Matter of the Termination of the Parent-Child Relationship of L.D.C. & J.C. (Child.) & M.C. (Mother) M.C. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

In the Matter of the Involuntary Termination of the Parent-Child Relationship of E.B. & W.B. (Minor Child.), & A.C. (Father) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2019).

— Ind. Code § 31-35-2-4(b) — 117 cases

Term. of Parent-Child Rel. of I.A. J.H. v. IDCS, 934 N.E.2d 1127 (Ind. 2010). “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). The record shows that I.”

Bester v. Lake Cnty. Off. of Fam. & Child., 839 N.E.2d 143 (Ind. 2005). “Indiana Code § 31-35-2-4(b)(@Q) requires that a petition to terminate a parent-child relationship involving a child in need of services must allege that: (A) one (1) of the following exists: (i) The child has been removed from the parent for at least six (6) months under a…”

In Re Ks, 750 N.E.2d 832 (Ind. Ct. App. 2001).

T.Q. v. Indiana Dep't of Child Servs., 996 N.E.2d 385 (Ind. Ct. App. 2013). “The timing requirements provided by Ind. Code § 31-35-2-4 (b)(2)(A) are in place for a reason, namely, to insure that parents have an adequate opportunity to make the corrections necessary in order to keep their family unit intact.”

In Re the Involuntary Termination of the Parent-Child Relationship of R.S., (Minor Child), & R.S. (Father) v. Marion Cnty. Dep't of Child Servs. & Child Advocates, Inc., 56 N.E.3d 625 (Ind. 2016).

— Ind. Code § 31-35-2-4(b)(1)(D) — 1 case

In the Matter of the Term. of the Parent-Child Rel. of J.C., Et.C. & El.C. S.C. v. Indiana Dep't of Child Servs., 994 N.E.2d 278 (Ind. Ct. App. 2013). “Pursuant to Ind.Code § 31-35-2-4(b)(1)(D), DCS must provide sufficient evidence there is a satisfactory plan for the care and treatment of the child.”

— Ind. Code § 31-35-2-4(b)(2) — 445 cases

In the Matter of the Termination of the Parent-Child Relationship of E.M. & El.M., E.M. v. Indiana Dep't of Child Servs., 4 N.E.3d 636 (Ind. 2014). “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). Where the State fails to prove “any one” of the statutory elements “it is not entitled to a judgment terminating parental rights.”

Involuntary Termination of Parent-Child Relationship of K.E. v. Indiana Dep't of Child Servs., 39 N.E.3d 641 (Ind. 2015). “Conclusion Without clear and convincing evidence to support each of the factors set out in Indiana Code § 31-35-2-4(b), we cannot terminate a parent-child relationship.”

R.C. v. Indiana Dep't of Child Servs., 989 N.E.2d 1225 (Ind. 2013). “2002)); I.C. § 31-35-2-4(b)(2). In this case the trial court determined that both allegations were satisfied.”

Term. of Parent-Child Rel. of I.A. J.H. v. IDCS, 934 N.E.2d 1127 (Ind. 2010). “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). The record shows that I.”

In Re Termination of Relationship of DD, 804 N.E.2d 258 (Ind. Ct. App. 2004). “" Ind.Code § 31-35-2-4 (emphasis added). The trial court also found a reasonable probability that the reasons for continued placement outside of Mother's home would not be remedied, and this finding is not clearly erroneous.”

— Ind. Code § 31-35-2-4(b)(2)(A) — 56 cases

Termination: VG v. Indiana Dep't of Child Servs., 69 N.E.3d 464 (Ind. 2017). “” Ind. Code § 31-35-2-4 (b)(2)(A)(i) (Supp.”

Termination: KC v. Indiana Dep't of Child Servs., 71 N.E.3d 898 (Ind. Ct. App. 2017). “Ind. Code § 31-35-2-4 (b)(2). DCS must provide clear and convincing proof of these allegations.”

A.M. v. Indiana Dep't of Child Servs., 45 N.E.3d 471 (Ind. Ct. App. 2015). “Ind,Code§ 31-35-2-4,5. . "[I]n the case of a child-who has been in foster care under the responsibility of the State for 15 of the most recent 22 months, .”

Term. of Parent-Child Rel. of: Q.M. & E.M., Minor Child., B.M., Father v. Indiana Dept. of Child Servs., 974 N.E.2d 1021 (Ind. Ct. App. 2012).

— Ind. Code § 31-35-2-4(b)(2)(A)(D) — 1 case

In Re Wb, 772 N.E.2d 522 (Ind. Ct. App. 2002).

— Ind. Code § 31-35-2-4(b)(2)(A)(Gi) — 1 case

Everhart v. Scott Cnty. Off. of Fam. & Child., 779 N.E.2d 1225 (Ind. Ct. App. 2002).

— Ind. Code § 31-35-2-4(b)(2)(A)(i) — 18 cases

Termination: KC v. Indiana Dep't of Child Servs., 71 N.E.3d 898 (Ind. Ct. App. 2017). “Ind. Code § 31-35-2-4 (b)(2). DCS must provide clear and convincing proof of these allegations.”

In Re Wb, 772 N.E.2d 522 (Ind. Ct. App. 2002).

In Re Dq, 745 N.E.2d 904 (Ind. Ct. App. 2001).

In Re Dd, 962 N.E.2d 70 (Ind. Ct. App. 2011).

— Ind. Code § 31-35-2-4(b)(2)(A)(ii) — 3 cases

T.Y.T. v. Allen Cnty. Div. of Fam. & Child., 714 N.E.2d 752 (Ind. Ct. App. 1999).

In the Matter of the Termination of the Parent-Child Relationship of A.S.: K.S. v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2013).

In the Matter of the Involuntary Term. of the Parent-Child Rel. of P.M., A.T. & A.P., Minor Child., & their Mother, S.T, S.T. v. Indiana Dept. of Child Servs. (Ind. Ct. App. 2013).

— Ind. Code § 31-35-2-4(b)(2)(A)(iii) — 17 cases

T.D. v. Indiana Dep't of Child Servs., 27 N.E.3d 1185 (Ind. Ct. App. 2015).

D.B. & V.G. v. Indiana Dep't of Child Servs., 61 N.E.3d 364 (Ind. Ct. App. 2016).

Termination: KC v. Indiana Dep't of Child Servs., 71 N.E.3d 898 (Ind. Ct. App. 2017). “Ind. Code § 31-35-2-4 (b)(2). DCS must provide clear and convincing proof of these allegations.”

Termination of Parent-Child Relationship of A.P. v. Porter Cnty. Off. of Fam. & Child., 734 N.E.2d 1107 (Ind. Ct. App. 2000).

— Ind. Code § 31-35-2-4(b)(2)(B) — 610 cases

R.C. v. Indiana Dep't of Child Servs., 989 N.E.2d 1225 (Ind. 2013). “2002)); I.C. § 31-35-2-4(b)(2). In this case the trial court determined that both allegations were satisfied.”

Term. of Parent-Child Rel. of I.A. J.H. v. IDCS, 934 N.E.2d 1127 (Ind. 2010). “” Ind. Code § 31-35-2-4 (b)(2)(B)(i). The record shows that I.”

McBride v. Monroe Cnty. Off. of Fam. & Child., 798 N.E.2d 185 (Ind. Ct. App. 2003). “] Ind.Code § 31-35-2-4(b)(2)(B). The OFC must also show that termination is in the best interests of the child.”

In the Termination of the Parent-Child Relationship of: S.S. (Minor Child) & L.M. (Mother) & Sa.S. (Father) v. The Indiana Dep't of Child Servs., 120 N.E.3d 605 (Ind. Ct. App. 2019).

In the Matter of the Termination of the Parent-Child Relationship of: A.D.S. & A.S. & L.S. v. The Indiana Dep't of Child Servs., 987 N.E.2d 1150 (Ind. Ct. App. 2013).

— Ind. Code § 31-35-2-4(b)(2)(B)(i) — 109 cases

R.C. v. Indiana Dep't of Child Servs., 989 N.E.2d 1225 (Ind. 2013). “2002)); I.C. § 31-35-2-4(b)(2). In this case the trial court determined that both allegations were satisfied.”

Term. of the Parent-Child Rel. of: B.H. & B.H. (Minor Child.), & T.H. (Mother) v. The Indiana Dept. of Child Servs., 989 N.E.2d 355 (Ind. Ct. App. 2013).

In Re Ai, 825 N.E.2d 798 (Ind. Ct. App. 2005).

In the Matter of the Term. of the Parent-Child Rel. of: D.W., K.K., Ke.K., & L.W. & J.K. v. The Indiana Dept. of Child Servs., 969 N.E.2d 89 (Ind. Ct. App. 2012).

A.B. & T.B. v. The Indiana Deaprtment of Child Servs., 61 N.E.3d 1182 (Ind. Ct. App. 2016).

— Ind. Code § 31-35-2-4(b)(2)(B)(ii) — 28 cases

R.C. v. Indiana Dep't of Child Servs., 989 N.E.2d 1225 (Ind. 2013). “2002)); I.C. § 31-35-2-4(b)(2). In this case the trial court determined that both allegations were satisfied.”

In the Matter of the Term. of the Parent-Child Rel. of A.P. & Au.P. M.H. & T.P. v. The Indiana Dept. of Child Servs., 981 N.E.2d 75 (Ind. Ct. App. 2012).

In re the Involuntary Termination of H.T., 901 N.E.2d 1118 (Ind. Ct. App. 2009).

In Re Ht, 901 N.E.2d 1118 (Ind. Ct. App. 2009).

In the Matter of the Term. of the Parent-Child Relationship of: B.G. & Br. G. (Minor Child.), K.F. & Z.G. v. Ind. Dept. of Child Servs. (mem. dec.) (Ind. Ct. App. 2016).

— Ind. Code § 31-35-2-4(b)(2)(B)(iii) — 11 cases

In the Matter of S.D., Alleged to be a Child in Need of Servs. J.B. v. Indiana Dep't of Child Servs., 2 N.E.3d 1283 (Ind. 2014).

In the Matter of: N.C. (Minor Child), Child in Need of Servs. & J.M. (Father) v. The Indiana Dep't of Child Servs., 72 N.E.3d 519 (Ind. Ct. App. 2017).

In the Matter of J.B. & L.B.: J.J. (Mother) v. The Indiana Dep't of Child Servs., 61 N.E.3d 308 (Ind. Ct. App. 2016).

S.C. v. Indiana Dep't of Child Servs., Local Knox Cnty. Off. (mem. dec.) (Ind. Ct. App. 2017).

In Re the Termination of the Parent-Child Relationship of: K.C.C. & K.M.C. (Minor Child.) & V.P. (Father) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2017).

— Ind. Code § 31-35-2-4(b)(2)(C) — 76 cases

Phelps v. Sybinsky, 736 N.E.2d 809 (Ind. Ct. App. 2000).

In Re Hl, 915 N.E.2d 145 (Ind. Ct. App. 2009).

C.B. v. Indiana Dep't of Child Servs., 952 N.E.2d 209 (Ind. Ct. App. 2011).

D.B. & V.G. v. Indiana Dep't of Child Servs., 61 N.E.3d 364 (Ind. Ct. App. 2016).

Ferbert v. Marion Cnty. Off. of Fam. & Child., 743 N.E.2d 766 (Ind. Ct. App. 2001).

— Ind. Code § 31-35-2-4(b)(2)(D) — 48 cases

Involuntary Termination of Parent-Child Relationship of A.J. v. Marion Cnty. Off. of Fam. & Child., 881 N.E.2d 706 (Ind. Ct. App. 2008).

A.F. v. Marion Cnty. Off. of Fam. & Child., 762 N.E.2d 1244 (Ind. Ct. App. 2002).

C.B. v. Indiana Dep't of Child Servs., 952 N.E.2d 209 (Ind. Ct. App. 2011).

Lanny B. v. Marion Cnty. Dep't of Child Servs., 889 N.E.2d 326 (Ind. Ct. App. 2008).

In Re Lb, 889 N.E.2d 326 (Ind. Ct. App. 2008).

— Ind. Code § 31-35-2-4(b)(2)(a) — 1 case

Term. of Parent-Child Rel. of: Q.M. & E.M., Minor Child., B.M., Father v. Indiana Dept. of Child Servs., 974 N.E.2d 1021 (Ind. Ct. App. 2012).

— Ind. Code § 31-35-2-4(b)(2)(c) — 1 case

In re the Termination of the Parent-Child Relationship of R.J. (Minor Child) & J.J. (Mother) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

— Ind. Code § 31-35-2-4(b)(2)(i) — 2 cases

In re the Involuntary Termination of the Parent-Child Relationship of Ja.M., X.M., Je.M., & R.M. (Minor Child.) , & S.J. (Mother) & D.M. (Father) (mem. dec.) (Ind. Ct. App. 2015).

In Re the Termination of the Parent-Child Relationship of: E.B. (a Minor Child) & B.H. (Father) v. Ind. Dept. of Child Servs. (mem. dec.) (Ind. Ct. App. 2015).

— Ind. Code § 31-35-2-4(b)(3) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of L.D.C. & J.C. (Child.) & M.C. (Mother) M.C. (Mother) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2018).

— Ind. Code § 31-35-2-4(b)(B) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of B.D., Mother, & S.D., Minor Child, B.D. v. Indiana Dep't of Child Servs., & Child Advocates, Inc. (mem. dec.) (Ind. Ct. App. 2018).

— Ind. Code § 31-35-2-4(b)(B)(i) — 1 case

In the Matter of the Term. of the Parent-Child Relationship of: C.G., I.G., & S.G. (Minor Child.), & J.G. (Mother) v. The Ind. Dept. of Child Servs. (mem. dec.) (Ind. Ct. App. 2015).

— Ind. Code § 31-35-2-4(b)(B)(iii) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of: K.A. (Minor Child) & K.A. (Mother),& C.A. (Father) v. The Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2020).

— Ind. Code § 31-35-2-4(b)(ii) — 1 case

In the Matter of the Termination of the Parent-Child Relationship of A.B. (Minor Child) D.F. (Father) v. Indiana Dep't of Child Servs. (mem. dec.) (Ind. Ct. App. 2019).

— Ind. Code § 31-35-2-4(b)(l)(C) — 1 case

— Ind. Code § 31-35-2-4(c) — 1 case

Termination: A L v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(c)(1) — 1 case

Termination: T M v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(c)(3) — 1 case

Termination: T M v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(d) — 1 case

Termination: A L v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(d)(2) — 1 case

Termination: T M v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(d)(3) — 2 cases

Termination: T M v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

Termination: A L v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

— Ind. Code § 31-35-2-4(d)(5) — 1 case

CHINS: K R v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2024).

— Ind. Code § 31-35-2-4(d)(8) — 1 case

Termination: T M v. Indiana Dep't of Child Servs. (Ind. Ct. App. 2025).

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.