CHINS: A A v. Indiana Department of Child Services

CourtIndiana Court of Appeals
DecidedJune 10, 2024
Docket23A-JC-00923
StatusPublished

This text of CHINS: A A v. Indiana Department of Child Services (CHINS: A A v. Indiana Department of Child Services) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CHINS: A A v. Indiana Department of Child Services, (Ind. Ct. App. 2024).

Opinion

FILED Jun 10 2024, 10:24 am

CLERK Indiana Supreme Court Court of Appeals IN THE and Tax Court

Court of Appeals of Indiana In the Matter of R.L. Jr., M.L., T.A., An.A., Q.A., Z.L., I.L., and A.L. (Minor Children), Children in Need of Services, and A.A. (Mother), R.L., Sr. (Father), and O.A. (Father), Appellants-Respondents

v.

Indiana Department of Child Services, Appellee-Petitioner

June 10, 2024 Court of Appeals Case No. 23A-JC-923 Appeal from the Lawrence Circuit Court The Honorable Nathan Nikirk, Judge Trial Court Cause No. 47C01-2302-JC-44 47C01-2302-JC-45 47C01-2302-JC-46

Court of Appeals of Indiana | Opinion 23A-JC-923 | June 10, 2024 Page 1 of 31 47C01-2211-JC-385 47C01-2211-JC-386 47C01-2211-JC-387 47C01-2211-JC-388 47C01-2211-JC-391

Opinion by Judge Kenworthy Chief Judge Altice and Judge Weissmann concur.

Kenworthy, Judge.

Case Summary [1] Eight children in a blended family were adjudicated children in need of services

(“CHINS”). O.A., father of three of the children, appeals the judgment, asking

what the Indiana Department of Child Services (“DCS”) must allege when it

files a new CHINS petition after an earlier petition is dismissed without

prejudice for a procedural reason. R.L., father of the other five children, and

A.A., mother of O.A.’s three children and three of R.L.’s children, also appeal

the judgment, asking whether the trial court erred in entering pre-disposition no

contact orders (“NCOs”) and denying their motion to disqualify the DCS

attorney. They also claim there was structural error in the proceedings.

[2] We discern no error in the procedural issues raised by the parents, and we

decline to find structural error in this CHINS proceeding. As the parents do not

challenge the trial court’s findings of fact, the sufficiency of the evidence

Court of Appeals of Indiana | Opinion 23A-JC-923 | June 10, 2024 Page 2 of 31 supporting the CHINS adjudications, or the contents of the dispositional orders,

we affirm the trial court’s judgment.

Facts and Procedural History 1 The Parties and the Filing of CHINS Petitions

[3] Father R.L. and mother S.C. 2 have two children (the “Oldest Children”)

together:

R.L. Jr., born February 9, 2009, 13 years old 3 M.L., born June 9, 2010, 12 years old

Father O.A. and mother A.A. have three children (the “Middle Children”)

T.A., born February 2, 2012, 10 years old An.A., born August 18, 2014, 8 years old Q.A., born December 22, 2016, 5 years old

And R.L. and A.A. have three children (the “Youngest Children”) together:

Z.L., born April 19, 2019, 3 years old I.L., born April 8, 2020, 2 years old A.L., born May 7, 2021, 1 year old

1 We heard oral argument in this case on March 26, 2024, in our courtroom at the Indiana Statehouse. We thank counsel for their preparation and helpful presentations. 2 S.C. participated in the CHINS proceedings but does not participate in this appeal. 3 The children’s ages listed here are as of the time this case began.

Court of Appeals of Indiana | Opinion 23A-JC-923 | June 10, 2024 Page 3 of 31 [4] In 2022, all eight children lived with R.L. and A.A. (“Mother”). Mother’s

adult brother J.Z. also lived with them. In late 2022, DCS investigated a report

alleging the Oldest Children were victims of physical abuse in the home by

R.L., Mother, and J.Z. As a result of the investigation, DCS removed all the

children from the home on an emergency basis. The Oldest Children were

placed in relative care, the Middle Children were placed with O.A., and the

Youngest Children were placed in foster care. DCS sought permission to file

CHINS petitions, alleging, in part:

• The Oldest Children were routinely beaten with a paddle on the back and

buttocks or made to put their hands flat on a table while the paddle was

used in a chopping motion toward their hands.

• R.L., Mother, and J.Z. hit R.L. Jr. with a paddle on or about October 30,

2022, and he had severe bruising on his lower back and buttocks.

• M.L. was hit with a paddle on or about October 30, 2022, and had

bruising on his face.

• M.L. had bruising on his upper back from being kicked by R.L., on his

middle back from being punched by R.L., and bruising and scarring on

his upper left thigh from being hit by the paddle. He also had healed

blisters on his palms from being burned by R.L. with a lighter while

Mother held him down.

• The Oldest Children were hit on the hands with the paddle on November

1, 2022. X-rays of R.L. Jr.’s hands showed a broken finger.

Court of Appeals of Indiana | Opinion 23A-JC-923 | June 10, 2024 Page 4 of 31 • The Oldest Children were hit with the paddle and made to stay home

from school if they did not get their chores done.

• Mother made the children kneel on rice as punishment.

• The paddle was also used on the Middle Children, though to a lesser

degree.

[5] R.L., Mother, and O.A. appeared at an initial/detention hearing on November

4, 2022. The trial court appointed separate counsel for R.L. and Mother but

O.A. declined appointment of an attorney. After reviewing the reports and

hearing evidence, the court authorized DCS to file the CHINS petitions and

approved the children’s continued detention. 4

[6] DCS orally requested “a no contact order between [R.L. and Mother] and the

five oldest children,” noting there was a “criminal investigation going on.” Tr.

Vol. 2 at 50. The court granted DCS’ request but advised R.L. and Mother they

had the “right to revisit that no contact order at any point.” Id. The court

memorialized its ruling on DCS’ request as part of its written order on the

initial/detention hearing:

The Court also orders a No Contact Order between [the Oldest and Middle Children] and Mother . . . and [R.L.] until further Order of the Court. DCS is ordered to file its request pursuant to I.C. 31-34-25 et seq. or I.C. 31-32-13-1 to ensure the [clerk]

4 The CHINS petitions alleged all the children were CHINS pursuant to Indiana Code Section 31-34-1-1 (“Inability, Refusal or Neglect”), and the Oldest Children and Middle Children were also CHINS pursuant to Section 31-34-1-2 (“Act or Omission Seriously Endangering Physical or Mental Health”), and Section 31-34- 12-4 (rebuttable presumption of CHINS where child has been injured). Appellants’ Jt. App. Vol. 2 at 150–55.

Court of Appeals of Indiana | Opinion 23A-JC-923 | June 10, 2024 Page 5 of 31 properly documents said No Contact Orders in compliance with I.C. 5-2-9. Counsel for Mother . . . and [R.L.] may request a hearing on the No Contact Orders.

Appellants’ Jt. App. Vol. 2 at 161.

[7] Shortly after the initial hearing, DCS learned O.A. was letting the Middle

Children speak with Mother over the phone. DCS reported this to the court,

and in turn, the court amended its initial hearing order to make clear “no

contact” meant any direct or indirect communication, including by telephone.

Id. at 169.

[8] The eight CHINS cases ultimately proceeded to a consolidated fact-finding

hearing on February 23, 2023, after which the trial court adjudicated the

children as CHINS and issued dispositional orders. No party challenges on

appeal the merits of the CHINS adjudication or the contents of the dispositional

orders. Instead, Mother and R.L. jointly and O.A. separately raise issues

related to rulings the trial court made before the fact-finding hearing. Because

the relevant procedural history between the initial hearing in November 2022

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