Ind. Code » Title 31
Indiana Code

Ind. Code § 31-9-2-51 (2026)

"Hard to place child" or "hard to place children"

✓ current as of May 2026
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     Sec. 51. "Hard to place child" or "hard to place children", for purposes of IC 31-19 and IC 31-34, means a child who is or children who are disadvantaged:

(1) because of:

(A) ethnic background;

(B) race;

(C) color;

(D) language;

(E) physical, mental, or medical disability; or

(F) age; or

(2) because the child or children are members of a sibling group that should be placed in the same home.

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

As added by P.L.1-1997, SEC.1. Amended by P.L.200-1999, SEC.1; P.L.179-2025, SEC.5.

 

Notes of Decisions
Cited in 5 cases, 2006–2009 · leading case: M.H. v. C.R., 918 N.E.2d 736 (Ind. Ct. App. 2009).
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M.H. v. C.R., 918 N.E.2d 736 (Ind. Ct. App. 2009). · cites it 9× “" Ind.Code § 31-9-2-51. In this case, MH. and C.”
Marion Cnty. Div. of Indiana Dep't of Child Servs. v. S.M., 904 N.E.2d 203 (Ind. 2009). · cites it 6× “) In November 2005, Petitioner's lawyer moved again to amend the petition for adoption, and requested a final hearing.”
In Re Infant Girl W., 845 N.E.2d 229 (Ind. Ct. App. 2006). · cites it 2× “Ind.Code § 31-9-2-51. [5] OFC had not previously and did not at that time make a request to remove the Parents as M.”
Marion Cnty. Div. of Indiana Dep't of Child Servs. v. Melinger, 878 N.E.2d 331 (Ind. Ct. App. 2007). · cites it 16× “The court lacked authority to grant the adoption to a non-resident because the children were not “hard to place” pursuant to Ind.Code § 31-9-2-51; and 4. The court failed to comply with the Interstate Compact on the Placement of Children, Ind.”
R.K.H. v. Morgan Cnty. Off. of Fam. & Child., 845 N.E.2d 229 (Ind. Ct. App. 2006). · cites it 2× “Ind.Code § 31-9-2-51. . OFC had not previously and did not at that time make a request to remove the Parents as M.”
— Ind. Code § 31-9-2-51(1)(B) — 1 case
Marion Cnty. Div. of Indiana Dep't of Child Servs. v. S.M., 904 N.E.2d 203 (Ind. 2009). “) In November 2005, Petitioner's lawyer moved again to amend the petition for adoption, and requested a final hearing.”
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