Indiana Code

Ind. Code § 34-23-2-1 (2026)

Injury or death of child; action by parent or guardian

✓ current as of May 2026
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     Sec. 1. (a) This section does not apply to an abortion performed in compliance with:

(1) IC 16-34; or

(2) IC 35-1-58.5 (before its repeal).

     (b) As used in this section, "child" means an unmarried individual without dependents who is:

(1) less than twenty (20) years of age; or

(2) less than twenty-three (23) years of age and is enrolled in a postsecondary educational institution or a career and technical education school or program that is not a postsecondary educational program.

The term includes a fetus that has attained viability (as defined in IC 16-18-2-365).

     (c) An action may be maintained under this section against the person whose wrongful act or omission caused the injury or death of a child. The action may be maintained by:

(1) the father and mother jointly, or either of them by naming the other parent as a codefendant to answer as to his or her interest;

(2) in case of divorce or dissolution of marriage, the person to whom custody of the child was awarded; and

(3) a guardian, for the injury or death of a protected person.

     (d) In case of death of the person to whom custody of a child was awarded, a personal representative shall be appointed to maintain the action for the injury or death of the child.

     (e) In an action brought by a guardian for an injury to a protected person, the damages inure to the benefit of the protected person.

     (f) In an action to recover for the death of a child, the plaintiff may recover damages:

(1) for the loss of the child's services;

(2) for the loss of the child's love and companionship; and

(3) to pay the expenses of:

(A) health care and hospitalization necessitated by the wrongful act or omission that caused the child's death;

(B) the child's funeral and burial;

(C) the reasonable expense of psychiatric and psychological counseling incurred by a surviving parent or minor sibling of the child that is required because of the death of the child;

(D) uninsured debts of the child, including debts for which a parent is obligated on behalf of the child; and

(E) the administration of the child's estate, including reasonable attorney's fees.

     (g) Damages may be awarded under this section only with respect to the period of time from the death of the child until:

(1) the date that the child would have reached:

(A) twenty (20) years of age; or

(B) twenty-three (23) years of age, if the child was enrolled in a postsecondary educational institution or in a career and technical education school or program that is not a postsecondary educational program; or

(2) the date of the child's last surviving parent's death;

whichever first occurs.

     (h) Damages may be awarded under subsection (f)(2) only with respect to the period of time from the death of the child until the date of the child's last surviving parent's death.

     (i) Damages awarded under subsection (f)(1), (f)(2), (f)(3)(C), and (f)(3)(D) inure to the benefit of:

(1) the father and mother jointly if both parents had custody of the child;

(2) the custodial parent, or custodial grandparent, and the noncustodial parent of the deceased child as apportioned by the court according to their respective losses; or

(3) a custodial grandparent of the child if the child was not survived by a parent entitled to benefit under this section.

However, a parent or grandparent who abandoned a deceased child while the child was alive is not entitled to any recovery under this chapter.

     (j) This section does not affect or supersede any other right, remedy, or defense provided by any other law.

[Pre-1998 Recodification Citation: 34-1-1-8.]

As added by P.L.1-1998, SEC.18. Amended by P.L.2-2007, SEC.373; P.L.234-2007, SEC.169; P.L.3-2008, SEC.242; P.L.129-2009, SEC.8.

 

IC 34-24ARTICLE 24. CIVIL PROCEEDINGS RELATED TO CRIMINAL ACTIVITIES

 

           Ch. 1.Forfeiture of Property Used in Violation of Certain Criminal Statutes
           Ch. 2.Civil Remedies for Racketeering Activity
           Ch. 3.Treble Damages Allowed in Certain Civil Actions by Crime Victims
           Ch. 4.Drug Dealer Liability
           Ch. 5.Civil Fertility Fraud

 

IC 34-24-1Chapter 1. Forfeiture of Property Used in Violation of Certain Criminal Statutes

 

           34-24-1-0.1Repealed
           34-24-1-1Seizure of vehicles and property commonly used as consideration for controlled substance or felony terrorist offenses; seizure of tobacco products and personal property
           34-24-1-2Seizure procedure; custody; provisional release
           34-24-1-3Action for forfeiture; procedure
           34-24-1-4Hearing; disposition of property; distribution of funds
           34-24-1-4.5Prosecuting attorney reports concerning transferred property
           34-24-1-5Determination of secured interest and appraised value; disposition of property; payment
           34-24-1-6Public sale of property; publication of notice; proceeds
           34-24-1-7Court order; filing; effect
           34-24-1-8Retention of attorney to bring action; compensation agreements
           34-24-1-9Disposition of seized property; expenditures of money

 

Notes of Decisions
Cited in 77 cases (11 in the last 5 years), 1998–2026 · leading case: Horn v. Hendrickson, 824 N.E.2d 690 (Ind. Ct. App. 2005).
Horn v. Hendrickson, 824 N.E.2d 690 (Ind. Ct. App. 2005). · cites it 25× “Whether a viable fetus is a "child" under Indiana's child wrongful death statute, Indiana Code Section 34-23-2-1 ("the statute"). 2. Whether the statute, as interpreted by our supreme court in Bolin v.”
Robinson v. Wroblewski, 704 N.E.2d 467 (Ind. 1998). · cites it 24× “Ind.Code § 34-23-2-1 (1998)(emphasis added).”
Randles v. Indiana Patient's Comp. Fund, 860 N.E.2d 1212 (Ind. Ct. App. 2007). · cites it 32× “Ezra Douglas has a claim for damages for the death of Sean pursuant to Indiana’s Wrongful Death of a Child Statute, Ind.Code § 34-23-2-1. The Court finds and concludes that Sean was a “child” within the meaning of subsection (a) of that statute.”
Durham Ex Rel. Est. of Wade v. U-Haul Int'l, 745 N.E.2d 755 (Ind. 2001). · cites it 7× “I.C. § 34-23-2-1. [2] The 1851 Constitution created the Supreme Court, circuit courts, and gave the legislature the power to create other "inferior courts.”
McCabe v. Comm'r, Indiana Dep't of Ins., 949 N.E.2d 816 (Ind. 2011). · cites it 8× “Ind. Code § 34-23-2-1 (enacted in 1998 and amended in 2007, 2008, and 2009).”
Bolin v. Wingert, 764 N.E.2d 201 (Ind. 2002). · cites it 4× “Ind.Code Ann. § 34-23-2-1 (West 1998). 2 .”
Est. of Sears Ex Rel. Sears v. Griffin, 771 N.E.2d 1136 (Ind. 2002). · cites it 8× “[2] Ind. Code Ann. § 34-23-2-1 (West 1999). The CWDS therefore allows recovery without proof of dependency or the necessity of opening an estate.”
Spangler v. Bechtel, 958 N.E.2d 458 (Ind. 2011). · cites it 4× “In granting the motion, the trial court concluded: (a) that the plaintiffs’ claims for emotional distress could not proceed under the CWDA because they were based on the death of an unborn child, which was not a “child” for the purposes of the CWDA; (b) that the plaintiffs did…”
Angel Shores Mobile Home Park, Inc. v. John Crays & Megan Crays, 78 N.E.3d 718 (Ind. Ct. App. 2017). · cites it 14× “On February 16, 2016, the trial court ordered Angel Shores to pay the Crays’ attorney’s fees and litigation expenses, stating: The matter having come before the Court on [the Crays’] Motion for Attorney Fees and Costs, the Court hereby finds that these elements of damages are…”
Ledbetter v. Ball Mem'l Hosp., 724 N.E.2d 1113 (Ind. Ct. App. 2000). · cites it 8× “…Constitution as applied to bar the Ledbetters’ claim. Judgment affirmed. SULLIVAN, J., and STATON, J., concur. 1 . Ind.Code § 34-23-2-1 et seq.”
Lillian Parsley, as the Guardian, Grandparent, & Next Friend of Robert Parsley v. MGA Fam. Grp., Inc., H Props. LLP, Mark Snedeker, & Video Tech/Direct Maytag HAC, 103 N.E.3d 651 (Ind. Ct. App. 2018). · cites it 8× “Ind. Code § 34-23-2-1 . The only provision under which Lillian could maintain an action is (c)(3) as "a guardian, for the injury or death of a protected person.”
Armstrong v. Federated Mut. Ins. Co., 785 N.E.2d 284 (Ind. Ct. App. 2003). · cites it 4× “Their complaint was brought under the Indiana Child Wrongful Death Act, Ind.Code Ann. § 34-23-2-1, et seq. (West 1999).”
— Ind. Code § 34-23-2-1(a) — 5 cases
Horn v. Hendrickson, 824 N.E.2d 690 (Ind. Ct. App. 2005). “Whether a viable fetus is a "child" under Indiana's child wrongful death statute, Indiana Code Section 34-23-2-1 ("the statute"). 2. Whether the statute, as interpreted by our supreme court in Bolin v.”
Robinson v. Wroblewski, 704 N.E.2d 467 (Ind. 1998). “Ind.Code § 34-23-2-1 (1998)(emphasis added).”
Est. of Sears Ex Rel. Sears v. Griffin, 771 N.E.2d 1136 (Ind. 2002). “[2] Ind. Code Ann. § 34-23-2-1 (West 1999). The CWDS therefore allows recovery without proof of dependency or the necessity of opening an estate.”
Randles v. Indiana Patient's Comp. Fund, 860 N.E.2d 1212 (Ind. Ct. App. 2007). “Ezra Douglas has a claim for damages for the death of Sean pursuant to Indiana’s Wrongful Death of a Child Statute, Ind.Code § 34-23-2-1. The Court finds and concludes that Sean was a “child” within the meaning of subsection (a) of that statute.”
Howard v. E & B Paving, Inc., 920 N.E.2d 693 (Ind. Ct. App. 2010).
— Ind. Code § 34-23-2-1(b) — 2 cases
Minix v. Canarecci, 956 N.E.2d 62 (Ind. Ct. App. 2011).
Est. of Sears Ex Rel. Sears v. Griffin, 752 N.E.2d 210 (Ind. Ct. App. 2001).
— Ind. Code § 34-23-2-1(b)(2) — 2 cases
City of Terre Haute v. Simpson, 746 N.E.2d 359 (Ind. Ct. App. 2001).
— Ind. Code § 34-23-2-1(b)(3) — 1 case
City of Terre Haute v. Simpson, 746 N.E.2d 359 (Ind. Ct. App. 2001).
— Ind. Code § 34-23-2-1(c) — 5 cases
Randles v. Indiana Patient's Comp. Fund, 860 N.E.2d 1212 (Ind. Ct. App. 2007). “Ezra Douglas has a claim for damages for the death of Sean pursuant to Indiana’s Wrongful Death of a Child Statute, Ind.Code § 34-23-2-1. The Court finds and concludes that Sean was a “child” within the meaning of subsection (a) of that statute.”
Minix v. Canarecci, 956 N.E.2d 62 (Ind. Ct. App. 2011).
Angel Shores Mobile Home Park, Inc. v. John Crays & Megan Crays, 78 N.E.3d 718 (Ind. Ct. App. 2017). “On February 16, 2016, the trial court ordered Angel Shores to pay the Crays’ attorney’s fees and litigation expenses, stating: The matter having come before the Court on [the Crays’] Motion for Attorney Fees and Costs, the Court hereby finds that these elements of damages are…”
Hill-Jackson v. FAF, INC., 808 F. Supp. 2d 1083 (S.D. Ind. 2011).
Bruce v. Barnets, Inc. (S.D. Ind. 2021).
— Ind. Code § 34-23-2-1(c)(1) — 2 cases
Angel Shores Mobile Home Park, Inc. v. John Crays & Megan Crays, 78 N.E.3d 718 (Ind. Ct. App. 2017). “On February 16, 2016, the trial court ordered Angel Shores to pay the Crays’ attorney’s fees and litigation expenses, stating: The matter having come before the Court on [the Crays’] Motion for Attorney Fees and Costs, the Court hereby finds that these elements of damages are…”
— Ind. Code § 34-23-2-1(c)(3) — 1 case
Lillian Parsley, as the Guardian, Grandparent, & Next Friend of Robert Parsley v. MGA Fam. Grp., Inc., H Props. LLP, Mark Snedeker, & Video Tech/Direct Maytag HAC, 103 N.E.3d 651 (Ind. Ct. App. 2018). “Ind. Code § 34-23-2-1 . The only provision under which Lillian could maintain an action is (c)(3) as "a guardian, for the injury or death of a protected person.”
— Ind. Code § 34-23-2-1(d) — 1 case
Angel Shores Mobile Home Park, Inc. v. John Crays & Megan Crays, 78 N.E.3d 718 (Ind. Ct. App. 2017). “On February 16, 2016, the trial court ordered Angel Shores to pay the Crays’ attorney’s fees and litigation expenses, stating: The matter having come before the Court on [the Crays’] Motion for Attorney Fees and Costs, the Court hereby finds that these elements of damages are…”
— Ind. Code § 34-23-2-1(e) — 3 cases
Robinson v. Wroblewski, 704 N.E.2d 467 (Ind. 1998). “Ind.Code § 34-23-2-1 (1998)(emphasis added).”
Durham Ex Rel. Est. of Wade v. U-Haul Int'l, 745 N.E.2d 755 (Ind. 2001). “I.C. § 34-23-2-1. [2] The 1851 Constitution created the Supreme Court, circuit courts, and gave the legislature the power to create other "inferior courts.”
Randles v. Indiana Patient's Comp. Fund, 860 N.E.2d 1212 (Ind. Ct. App. 2007). “Ezra Douglas has a claim for damages for the death of Sean pursuant to Indiana’s Wrongful Death of a Child Statute, Ind.Code § 34-23-2-1. The Court finds and concludes that Sean was a “child” within the meaning of subsection (a) of that statute.”
— Ind. Code § 34-23-2-1(f) — 5 cases
Robinson v. Wroblewski, 704 N.E.2d 467 (Ind. 1998). “Ind.Code § 34-23-2-1 (1998)(emphasis added).”
Loparex, LLC v. MPI Release Tech., LLC, 964 N.E.2d 806 (Ind. 2012).
Forte v. Connerwood Healthcare, Inc., 745 N.E.2d 796 (Ind. 2001).
Minix v. Canarecci, 956 N.E.2d 62 (Ind. Ct. App. 2011).
Indiana Patients Comp. Fund v. Brown, 934 N.E.2d 168 (Ind. Ct. App. 2010).
— Ind. Code § 34-23-2-1(g) — 1 case
— Ind. Code § 34-23-2-1(h)(2) — 1 case
Dameron v. City of Scottsburg, Ind., 36 F. Supp. 2d 821 (S.D. Ind. 1998).
— Ind. Code § 34-23-2-1(i) — 1 case
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