In the Matter of the Termination of the Parent-Child Relationship of A.T., Minor Child, and J.M., Father v. Department of Child Services (mem. dec.)

CourtIndiana Court of Appeals
DecidedFebruary 24, 2016
Docket71A03-1509-JT-1328
StatusPublished

This text of In the Matter of the Termination of the Parent-Child Relationship of A.T., Minor Child, and J.M., Father v. Department of Child Services (mem. dec.) (In the Matter of the Termination of the Parent-Child Relationship of A.T., Minor Child, and J.M., Father v. Department of Child Services (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
In the Matter of the Termination of the Parent-Child Relationship of A.T., Minor Child, and J.M., Father v. Department of Child Services (mem. dec.), (Ind. Ct. App. 2016).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be Feb 24 2016, 10:01 am

regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral estoppel, or the law of the case.

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Charles W. Lahey Gregory F. Zoeller South Bend, Indiana Attorney General of Indiana

Robert J. Henke James D. Boyer Deputy Attorneys General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

In the Matter of the Termination February 24, 2016 of the Parent-Child Relationship Court of Appeals Cause No. of A.T., Minor Child, 71A03-1509-JT-1328 Appeal from the St. Joseph Probate and, Court The Honorable James N. Fox, J.M., Father, Judge The Honorable Graham C. Polando, Magistrate Appellant-Respondent, Trial Court Cause No. v. 71J01-1402-JT-18

Court of Appeals of Indiana | Memorandum Decision 71A03-1509-JT-1328 | February 24, 2016 Page 1 of 9 Department of Child Services,

Appellee-Petitioner.

Barnes, Judge.

Case Summary [1] J.M. (“Father”) appeals the termination of his parental rights to A.T. We

affirm.

Issues [2] Father raises two issues, which we revise and restate as:

I. whether the proper procedures were followed under the Indian Child Welfare Act; and

II. whether the termination of Father’s parental rights is supported by clear and convincing evidence.

Facts [3] A.T. was born in February 2011 to Father and K.T. (“Mother”). The

Department of Child Services (“DCS”) filed a petition alleging that A.T. was a

child in need of services (“CHINS”) because she tested positive for drugs at her

birth and because Mother tested positive for cocaine. Father and Mother

Court of Appeals of Indiana | Memorandum Decision 71A03-1509-JT-1328 | February 24, 2016 Page 2 of 9 admitted that A.T. was a CHINS, and A.T. was not removed from their home

at that time. In June 2011, Father tested positive for cocaine, and the trial court

ordered him to leave the home and have supervised visitation. In October

2011, Father again tested positive for cocaine, and the trial court ordered him to

participate in an intensive drug treatment program.

[4] In May 2012, the trial court ordered that A.T. be placed in foster care due to her

parents’ persistent drug usage. Father continued to test positive for drugs, and

he was arrested in May 2013 for domestic battery against Mother. Father was

convicted and sentenced and later violated his probation. The trial court

ordered Father to participate in a domestic violence program, but he attended

only five of the twenty-six sessions. Father has not seen A.T. since June 2013.

[5] In March 2014, DCS filed a petition to terminate Father’s and Mother’s

parental rights to A.T. Mother voluntarily relinquished her parental rights to

A.T. In October 2014, Father disclosed to DCS for the first time that he

believed A.T. to have Indian ancestory. On November 12, 2014, DCS filed its

Indian Child Welfare Act (“ICWA”) notice and served the notice on Father,

the United States Secretary of the Interior, and the Apache tribe. DCS filed an

additional notice pursuant to the ICWA on December 29, 2014. The second

notice was served on Father and eight Apache tribes. In both notices, DCS

noted that Father “has claimed tribal eligibility for the Apache Tribe.” Ex. p.

207, 230. However, Father was unable to identify a tribal agent or specific area

of Apache. Father “was also unable to identify his paternal grandmother’s

maiden name, through whom he has claimed tribal eligibility.” Id.

Court of Appeals of Indiana | Memorandum Decision 71A03-1509-JT-1328 | February 24, 2016 Page 3 of 9 [6] In July 2015, the trial court conducted an evidentiary hearing on DCS’s petition

to terminate Father’s parental rights. The trial court entered findings of fact and

conclusions thereon terminating Father’s parental rights. Father now appeals.

Analysis I. Indian Child Welfare Act

[7] Father first argues that DCS failed to send the proper notice required by the

ICWA, 25 U.S.C. §§ 1901-1963. The power of state courts to conduct

termination proceedings involving children of Indian ancestry may be subject to

significant limitations under the ICWA. In re S.L.H.S., 885 N.E.2d 603, 612

(Ind. Ct. App. 2008). Although a trial court, after a proper petition for transfer

of the proceeding, is required to transfer to an Indian tribe’s jurisdiction any

proceeding to terminate the parental rights of an Indian child not domiciled or

residing within the reservation of the Indian child’s tribe, see 25 U.S.C. §

1911(b), the availability of this right to transfer is contingent on the applicability

of the ICWA to the proceeding. Id. “Thus, the party who seeks to invoke a

provision of the ICWA has the burden to show that the act applies in the

proceeding.” Id.

[8] Applicability of the ICWA depends on whether the proceeding to be transferred

involves an “Indian child,” which is defined as “any unmarried person who is

under age eighteen and is either (a) a member of an Indian tribe or (b) is eligible

for membership in an Indian tribe and is the biological child of a member of an

Indian tribe.” 25 U.S.C.A. § 1903(4). Here, there is no evidence that A.T. is a

Court of Appeals of Indiana | Memorandum Decision 71A03-1509-JT-1328 | February 24, 2016 Page 4 of 9 member of an Indian tribe or that she is eligible for membership and Father is a

member of an Indian tribe. Because Father has failed to provide any evidence

that A.T. is an Indian child within the purview of the ICWA, we conclude that

the ICWA did not apply to the proceedings to terminate Father’s parental

rights.

[9] Moreover, Father’s only argument on appeal is that DCS failed to send notice

to the Secretary of the Interior as required by 25 U.S.C. § 1912. Father

mentions only the December 2014 notice. However, DCS also sent a notice to

the Secretary of the Interior and the Apache tribe in November 2014. Father’s

argument fails.

II. Termination of Parental Rights

[10] Father challenges the termination of his parental rights to A.T. The Fourteenth

Amendment to the United States Constitution protects the traditional right of

parents to establish a home and raise their children. In re I.A., 934 N.E.2d 1127,

1132 (Ind. 2010). “A parent’s interest in the care, custody, and control of his or

her children is ‘perhaps the oldest of the fundamental liberty interests.’” Id.

(quoting Troxel v. Granville, 530 U.S. 57, 65, 120 S. Ct. 2054 (2000)). “Indeed

the parent-child relationship is ‘one of the most valued relationships in our

culture.’” Id. (quoting Neal v. DeKalb County Div. of Family & Children, 796

N.E.2d 280, 285 (Ind. 2003)). We recognize of course that parental interests

are not absolute and must be subordinated to the child’s interests when

determining the proper disposition of a petition to terminate parental rights. Id.

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Related

Term. of Parent-Child Rel. of I.A. J.H. v. IDCS
934 N.E.2d 1127 (Indiana Supreme Court, 2010)
Neal v. Termination of the Parent-Child Relationship of M.N.
796 N.E.2d 280 (Indiana Supreme Court, 2003)
Troxel v. Granville
530 U.S. 57 (Supreme Court, 2000)
Egly v. Blackford County Department of Public Welfare
592 N.E.2d 1232 (Indiana Supreme Court, 1992)

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