C.N. v. K.B. (mem. dec.)

CourtIndiana Court of Appeals
DecidedDecember 16, 2020
Docket20A-AD-1361
StatusPublished

This text of C.N. v. K.B. (mem. dec.) (C.N. v. K.B. (mem. dec.)) 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
C.N. v. K.B. (mem. dec.), (Ind. Ct. App. 2020).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be FILED regarded as precedent or cited before any Dec 16 2020, 8:47 am court except for the purpose of establishing CLERK the defense of res judicata, collateral Indiana Supreme Court Court of Appeals estoppel, or the law of the case. and Tax Court

ATTORNEY FOR APPELLANT Mark F. James Anderson, Agostino & Keller, P.C. South Bend, Indiana

IN THE COURT OF APPEALS OF INDIANA

C.N., December 16, 2020 Appellant-Respondent, Court of Appeals Case No. 20A-AD-1361 v. Appeal from the St. Joseph Probate Court K.B., The Honorable Appellee-Petitioner Jason Cichowicz, Judge Trial Court Cause No. 71J01-1906-AD-64

Vaidik, Judge.

Case Summary [1] C.N. appeals the trial court’s judgment that his consent to the adoption of

T.G.D. (“Child”) was irrevocably implied. We affirm. Court of Appeals of Indiana | Memorandum Decision 20A-AD-1361 | December 16, 2020 Page 1 of 6 Facts and Procedural History [2] S.B. (“Mother”) is the biological mother of Child, born in March 2016. Mother

believed C.N. to be Child’s biological father, but C.N. was not present for the

birth or listed on the birth certificate. Sometime after Child was born, Mother

“notified” C.N. and his mother that he is the father of Child. Tr. Vol. II p. 22.

However, C.N. had no contact with Child and paid no child support, and

paternity was never established. He also never registered with the putative-

father registry.

[3] In April 2019, when Child was three years old, Mother married K.B.

(“Stepmother”). In June, Stepmother filed a petition for adoption. Mother

executed a consent to the adoption and gave the adoption attorney C.N.’s

name. However, Mother did not provide C.N.’s address because she “did not

have that information[.]” Id. at 20. The adoption attorney and his legal assistant

located a potential address for C.N. online and, on July 9, 2019, sent notice of

Stepmother’s intent to adopt Child to that address, which was C.N.’s parents’

home. See Exs. A, B. This notice purported to be sent in compliance with the

form in Indiana Code section 31-19-4-5, but it did not include the last two

sentences of the form: “This notice complies with IC 31-19-4-5 but does not

exhaustively set forth a putative father’s legal obligations under the Indiana

adoption statutes. A person being served with this notice should consult the

Indiana adoption statutes.” Ind. Code § 31-19-4-5.

Court of Appeals of Indiana | Memorandum Decision 20A-AD-1361 | December 16, 2020 Page 2 of 6 [4] In July 2019, C.N. was incarcerated, but his parents told him about the notice.

On July 31, C.N. filed a motion to contest the adoption. In August, the trial

court appointed C.N. an attorney. A hearing on the motion to contest was held

in March 2020. Stepmother argued C.N. could not contest the adoption

because—under the putative-father-registry statutes—his consent to the

adoption was irrevocably implied when he failed to register with the putative-

father registry within the required period. See Ind. Code § 31-19-5-18. C.N.

countered the putative-father-registry statutes did not apply to him and

therefore his consent was not irrevocably implied under them. Specifically,

C.N. argued the statutes do not apply when the mother knows the putative

father’s name and address, and thus the statutes did not apply to him because

he claimed Mother knew his name and address. See Ind. Code § 31-19-5-1(b)

(stating the putative-father-registry statutes do not apply when “on or before the

date the child’s mother executes a consent to the child’s adoption, the child’s

mother discloses the name and address of the putative father to the attorney or

agency that is arranging the child’s adoption.”).

[5] In June, the trial court denied C.N.’s motion to contest, finding (1) the putative-

father-registry statutes applied to C.N. because Mother did not know his

address when she executed the consent to Child’s adoption and (2) C.N.’s

consent to the adoption was irrevocably implied because he did not register

with the putative-father registry within the required period. Appellant’s App.

Vol. II p. 64. The following month the trial court granted Stepmother’s petition

for adoption.

Court of Appeals of Indiana | Memorandum Decision 20A-AD-1361 | December 16, 2020 Page 3 of 6 [6] C.N. now appeals.

Discussion and Decision [7] At the outset, we note Stepmother did not file an appellee’s brief. Under that

circumstance, we do not undertake to develop the appellee’s arguments.

Branham v. Varble, 952 N.E.2d 744, 746 (Ind. 2011). Rather, we will reverse

upon an appellant’s prima facie showing of reversible error. Id.

[8] C.N. first argues his due-process rights were violated because the “Notice sent

by [Stepmother] did not fully comply with the Form of Notice required by I.C.

31-19-4-5.” Appellant’s Br. p. 7. It appears C.N., as an unregistered putative

father, was not even entitled to notice of the adoption. See Ind. Code §§ 31-19-4-

6, 31-19-5-18. But even if he was, Stepmother’s failure to strictly comply with

the form in Section 31-19-4-5 did not violate his due-process rights.

[9] The notice sent to C.N. omitted the last two sentences of the form in Section

31-19-4-5. However, the statute “requires substantial compliance with the form

of notice, not strict compliance.” In re Paternity of M.G.S., 756 N.E.2d 990, 1001

(Ind. Ct. App. 2001), trans denied. Substantial compliance with the notice

provision is “sufficient if the party receives notice which achieves that purpose

for which the statute was intended.” In re Adoption of J.T.A., 988 N.E.2d 1250,

1257 (Ind. Ct. App. 2013) (quoting In re Paternity of Baby Girl, 661 N.E.2d 873,

877 (Ind. Ct. App. 1996)), trans. denied. We have found insufficient notice where

deviations from the statutory form are misleading or omit materially significant

Court of Appeals of Indiana | Memorandum Decision 20A-AD-1361 | December 16, 2020 Page 4 of 6 elements. See Baby Girl, 661 N.E.2d at 878 (notice deficient because it misled

putative father “as to what was required of him”); J.T.A., 988 N.E.2d at 1257

(notice deficient because biological parent was not notified she must act within

thirty days or her consent would be implied). But that is not the scenario here.

The notice makes clear Stepmother intended to adopt Child and that C.N. had

to act within thirty days to protect his rights. C.N. makes no argument as to

how the omission of these lines misled him or failed to give him sufficient

notice. Indeed, C.N. filed a motion to contest within thirty days and was

appointed an attorney who represented him at the hearing. C.N.’s due-process

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Related

Branham v. Varble
952 N.E.2d 744 (Indiana Supreme Court, 2011)
In Re Paternity of MGS
756 N.E.2d 990 (Indiana Court of Appeals, 2001)
Matter of Paternity of Baby Girl, Born 6-7-94
661 N.E.2d 873 (Indiana Court of Appeals, 1996)
In the Matter of the Adoption of J.T.A. R.S.P. v. S.S.
988 N.E.2d 1250 (Indiana Court of Appeals, 2013)
In re: The Adoption of L.G.K. J.K. v. G.C.
113 N.E.3d 767 (Indiana Court of Appeals, 2018)

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C.N. v. K.B. (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/cn-v-kb-mem-dec-indctapp-2020.