Indiana Code

Ind. Code § 34-11-2-10 (2026)

Enforcement of child support obligations

✓ current as of May 2026
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     Sec. 10. An action to enforce a child support obligation must be commenced not later than ten (10) years after:

(1) the eighteenth birthday of the child; or

(2) the emancipation of the child;

whichever occurs first.

[Pre-1998 Recodification Citation: 34-1-2-1.6.]

As added by P.L.1-1998, SEC.6.

 

Notes of Decisions
Cited in 15 cases, 1998–2016 · leading case: Thurman v. Thurman, 777 N.E.2d 41 (Ind. Ct. App. 2002).
Thurman v. Thurman, 777 N.E.2d 41 (Ind. Ct. App. 2002). · cites it 10× “This section has since been recodified at Ind.Code § 34-11-2-10 (Burns. Code Ed. Repl.”
Connell v. Welty, 725 N.E.2d 502 (Ind. Ct. App. 2000). · cites it 10× “As Connell points out, I.C. § 34-11-2-10 was not in effect when both children were emancipated and the last support payment was due in 1991.”
Dore v. Dore, 782 N.E.2d 1015 (Ind. Ct. App. 2003). · cites it 10× “Ind.Code § 34-11-2-10. Thus, a more specific statute of limitations has been enacted to cover actions to enforce child support obligations See Thurman, 777 N.”
Lewis v. Rex Metal Craft, Inc., 831 N.E.2d 812 (Ind. Ct. App. 2005). · cites it 4× “, "must be commenced within" six or ten years); Ind.Code § 34-11-2-10 (action to enforce child support obligation "must be commenced" not later than ten years after eighteenth birthday or emancipation); Ind.”
Skolak v. Skolak, 895 N.E.2d 1241 (Ind. Ct. App. 2008). · cites it 8× “This specific statute of limitation was recodified in 1998 as Indiana Code section 34-11-2-10, and provides that "an action to enforce a child support obligation must be commenced not later than ten (10) years after: (1) the eighteenth birthday of the child; or (2) the…”
Bell v. Heflin, 383 P.3d 1031 (Wash. 2016). · cites it 2× “” Ind. Code § 34-11-2-10 . But Indiana also has a statute that states, “Every judgment and decree of any court .”
Garcia v. Garcia, 789 N.E.2d 993 (Ind. Ct. App. 2003). · cites it 6× “Our analysis on appeal was as follows: We observe initially that I.C. § 34-11-2-10 is a recodification of 1.”
In Re Paternity of SJJ, 877 N.E.2d 826 (Ind. Ct. App. 2007). · cites it 4× “Code § 34-11-2-10: An action to enforce a child support obligation must be commenced not later than ten (years) after: (1) the eighteenth birthday of the child; or (2) the emancipation of the child; whichever occurs first. S.J.J.'s eighteenth birthday occurred first, on October…”
Trent v. Trent, 829 N.E.2d 81 (Ind. Ct. App. 2005). · cites it 2× “2003) (discussing Ind.Code § 34-11-2-10 and Ind.Code § 34-11-1-2 (formerly Ind.”
Est. of Wilson v. Steward, 937 N.E.2d 826 (Ind. Ct. App. 2010). · cites it 5× “Code § 34-11-2-8 (real property execution actions "must be commenced within" six or ten years); Ind.”
McKenney v. State, 848 N.E.2d 1127 (Ind. Ct. App. 2006). · cites it 4× “, Ind.Code Ann. § 34-11-2-10 (West, PREMISE through 2005 1st Regular Sess.”
State Ex Rel. Albemarle Child Support Enf't Agency Ex Rel. George v. Bray, 503 S.E.2d 686 (N.C. Ct. App. 1998). “6 (1995), amended by Ind. Code Ann. § 34-11-2-10 (1998). Following both UIFSA and FFCCSOA, our courts must apply the statute of limitations of Indiana, not North Carolina, because Indiana’s is the longer of the two.”
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