CHINS: M C v. Indiana Department of Child Services

CourtIndiana Court of Appeals
DecidedJune 23, 2026
Docket26A-JC-00253
StatusPublished
AuthorJudge Brown

This text of CHINS: M C v. Indiana Department of Child Services (CHINS: M C 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: M C v. Indiana Department of Child Services, (Ind. Ct. App. 2026).

Opinion

IN THE

Court of Appeals of Indiana FILED In the Matter of: R.M. and A.R. (Minor Children), Jun 23 2026, 9:04 am and M.C. (Mother), CLERK Indiana Supreme Court Appellant-Respondent Court of Appeals and Tax Court

v.

Indiana Department of Child Services, Appellee-Petitioner

June 23, 2026 Court of Appeals Case No. 26A-JC-253 Appeal from the Decatur Circuit Court The Honorable Timothy B. Day, Judge Trial Court Cause Nos. 16C01-2510-JC-232 16C01-2510-JC-233

Opinion by Judge Brown

Court of Appeals of Indiana | Opinion 26A-JC-253 | June 23, 2026 Page 1 of 18 Judge Weissmann concurs. Judge Kenworthy dissents with separate opinion.

Brown, Judge.

[1] M.C. (“Mother”) appeals the trial court’s order adjudicating her minor

children, A.R. and R.M. (the “Children”), as children in need of services

(“CHINS”). We reverse.

Facts and Procedural History

[2] Mother and J.R. are the parents of A.R., born in January 2023. Mother and

K.M. are the parents of R.M., born in August 2025. In December 2024, the

Department of Child Services (“DCS”) received a report that alleged Mother

was using marijuana in the home and exposing A.R. to THC. Mother was

charged with possession of marijuana and, in January of 2025, A.R. tested

positive for THC. DCS filed a CHINS petition in February 2025, which was

later dismissed after A.R.’s hair follicle test came back inconclusive.

[3] When R.M. was born in August 2025, both Mother and R.M. tested positive

for THC at the hospital. Mother admitted to vaping THC while pregnant and

that she had been counseled about the potential risks of THC use during

pregnancy. Shortly thereafter, DCS visited Mother’s home and Mother

admitted to continued THC use and to breastfeeding while using THC. Mother

again tested positive for THC. DCS observed that the home had working

utilities and running water as well as ample amounts of food and baby supplies.

Court of Appeals of Indiana | Opinion 26A-JC-253 | June 23, 2026 Page 2 of 18 [4] On October 27, 2025, DCS received another report of neglect due to concerns

that Mother was using THC. DCS went to Mother’s home, and she admitted

that she continued to use THC. On October 28, 2025, DCS filed petitions

alleging that the Children were CHINS due to exposure to THC. On

November 7, 2025, a hair follicle test was conducted as to A.R. and showed

positive results for THC. On November 24, 2025, DCS filed amended CHINS

petitions to include the hair follicle results. In the amended petitions, DCS

alleged that A.R. was a CHINS pursuant to Ind. Code § 31-34-1-1, and that

R.M. was a CHINS pursuant to Ind. Code § 31-34-1-1 and Ind. Code § 31-34-1-

10.

[5] The trial court held a factfinding hearing on December 16, 2025. DCS

presented the testimony of Family Case Manager Chelsea Morgan (“FCM

Morgan”), Family Case Manager Devyn Dewhurst, and Dr. Isaiah Steffen.

Mother testified on her own behalf. Thereafter, the court adjudicated Children

as CHINS based upon its finding: “1) Both [C]hildren have been exposed to

THC.” Appellant’s Appendix Volume II at 135.

[6] The court held a dispositional hearing on December 29, 2025. On January 5,

2026, the court issued its dispositional decree. Among other things, the court

ordered Mother to complete a substance abuse assessment and follow all

treatments and recommendations. The court also ordered that both Mother

Court of Appeals of Indiana | Opinion 26A-JC-253 | June 23, 2026 Page 3 of 18 and the Children to participate in random drug screens. Mother filed her notice

of appeal on January 30, 2026. 1

Discussion

[7] Mother asserts that the trial court clearly erred in adjudicating Children as

CHINS. In reviewing a trial court’s determination that a child is in need of

services, we do not reweigh the evidence or judge the credibility of witnesses

and consider only the evidence which supports the court’s decision and

reasonable inferences drawn therefrom. In re S.D., 2 N.E.3d 1283, 1286-1287

(Ind. 2014), reh’g denied. As no statute expressly requires formal findings in a

CHINS factfinding order and because neither party requested them under Ind.

Trial Rule 52(A), we apply the two-tiered standard of whether the evidence

supports the findings, and whether the findings support the judgment to any

issue covered by the findings, and we review any remaining issues under the

general judgment standard pursuant to which a judgment “will be affirmed if it

can be sustained on any legal theory supported by the evidence.” Id. at 1287

1 We observe that an entry in Indiana’s Odyssey Case Management System (“Odyssey”) dated March 24, 2026, indicates that a review hearing scheduled for April 2, 2026, was canceled. Odyssey also indicates that counsel for DCS filed a Request for Wardship Termination under lower court cause number 16C01-2510-JC- 232 (“Cause No. 232”), which stated that: permanency for the child had been achieved through an approved reunification; Mother had shown negative drug screens and completed all requested services; CASA/GAL had been contacted and are in favor of wardship termination; and the case should be closed. On March 24, 2026, the trial court entered an Order on Wardship Termination under Cause No. 232 which ordered: “Jurisdiction in this matter is hereby terminated without prejudice and this cause of action is ordered closed. Any hearings currently scheduled in this matter are hereby vacated.” A similar order was entered in lower court cause number 16C01-2510-JC-233 (“Cause No. 233”). Nevertheless, we decline to find this case moot and proceed to address the merits. See In re S.D., 2 N.E.3d 1283, 1290 (Ind. 2014) (declining to find closed CHINS case moot and observing that a CHINS finding may have adverse consequences, including that “a CHINS finding can relax the State’s burden for terminating parental rights”).

Court of Appeals of Indiana | Opinion 26A-JC-253 | June 23, 2026 Page 4 of 18 (citation omitted). We will reverse a CHINS determination only if clearly

erroneous. In re D.J., 68 N.E.3d 574, 578 (Ind. 2017). A decision is clearly

erroneous if the record facts do not support the findings or if it applies the

wrong legal standard to properly found facts. Id.

[8] Ind. Code § 31-34-1-1 provides:

A child is a child in need of services if before the child becomes eighteen (18) years of age:

(1) the child’s physical or mental condition is seriously impaired or seriously endangered as a result of the inability, refusal, or neglect of the child’s parent, guardian, or custodian to supply the child with necessary food, clothing, shelter, medical care, education, or supervision:

(A) when the parent, guardian, or custodian is financially able to do so; or

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
CHINS: M C v. Indiana Department of Child Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chins-m-c-v-indiana-department-of-child-services-indctapp-2026.