In the Termination of the Parent-Child Relationship of: K.H. (Minor Child) and M.H. (Mother) v. Indiana Department of Child Services (mem. dec.)

CourtIndiana Court of Appeals
DecidedOctober 20, 2020
Docket20A-JT-894
StatusPublished

This text of In the Termination of the Parent-Child Relationship of: K.H. (Minor Child) and M.H. (Mother) v. Indiana Department of Child Services (mem. dec.) (In the Termination of the Parent-Child Relationship of: K.H. (Minor Child) and M.H. (Mother) v. Indiana 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.

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In the Termination of the Parent-Child Relationship of: K.H. (Minor Child) and M.H. (Mother) v. Indiana Department of Child Services (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 Oct 20 2020, 9:08 am court except for the purpose of establishing the defense of res judicata, collateral CLERK Indiana Supreme Court Court of Appeals estoppel, or the law of the case. and Tax Court

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Ana M. Quirk Curtis T. Hill, Jr. Muncie, Indiana Attorney General of Indiana

Katherine A. Cornelius Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

In the Termination of the Parent- October 20, 2020 Child Relationship of: Court of Appeals Case No. 20A-JT-894 K.H. (Minor Child), Appeal from the Delaware Circuit and Court M.H. (Mother), The Honorable Kimberly Dowling, Appellant-Respondent, Judge The Honorable Amanda Yonally, v. Magistrate Trial Court Cause No. Indiana Department of Child 18C02-1908-JT-191 Services, Appellee-Petitioner.

Altice, Judge. Court of Appeals of Indiana | Memorandum Decision 20A-JT-894 | October 20, 2020 Page 1 of 16 Case Summary [1] M.H. (Mother) appeals from the involuntary termination of her parental rights

to her minor child, K.H. (Child), challenging the sufficiency of the evidence

supporting the termination order. Mother also asserts that her due process

rights were violated when the trial court did not conduct a hearing prior to

ordering supervised visitation during the child in need of services (CHINS)

proceedings.

[2] We affirm.

Facts & Procedural [3] Mother and D.J. (Father) 1 are the biological parents of Child, born in June

2016. Child was born with fetal alcohol syndrome and tested positive for

marijuana at birth. On July 27, 2016, the Indiana Department of Child Services

(DCS) filed a CHINS petition, alleging that child was neglected or endangered

due to Mother’s drug use. 2 The petition also alleged that Mother submitted to a

drug screen on or around June 29, 2016, was positive for marijuana, and, after

agreeing to an informal adjustment, Mother failed to maintain contact with

1 Father passed away during the proceedings and before the termination petition was filed. We primarily focus on the facts related to Mother. 2 Ind. Code § 31-34-1-10 provides that a child born with a controlled substance in his or her body is a CHINS.

Court of Appeals of Indiana | Memorandum Decision 20A-JT-894 | October 20, 2020 Page 2 of 16 DCS. FCM Mischa Davis was assigned to the case in August 2016 and

remained continuously on it through the proceedings.

[4] On August 2, 2016, Mother was arrested for misdemeanor battery resulting in

bodily injury. On August 19, Mother admitted that Child was a CHINS, and

on October 14, 2016, the court adjudicated Child a CHINS. That same date,

the court issued a dispositional decree ordering that placement would remain

with Mother, and it ordered Mother to, among other things, maintain suitable,

safe housing; complete a substance abuse assessment and follow all

recommendations; not consume illegal substances; submit to random

drug/alcohol screens upon request; and provide Child with a safe, secure, and

nurturing environment free from abuse and neglect. In addition, the order

required Mother to permit DCS to enter her home upon request and make

Child available with or without an appointment. As of November 2016,

Mother had partially complied with the case plan.

[5] In December 2016, Child was removed from Mother’s home because Child was

endangered while in Mother’s care due to an incident of domestic violence

between Mother and Father. Initially, Child was placed in relative care with a

maternal aunt but Mother expressed concern about the aunt’s care for Child

and requested Child be placed in foster care. About two weeks later, on

December 28, the court ordered an emergency change of placement, and Child

was placed in licensed foster care, where Child has remained throughout the

Court of Appeals of Indiana | Memorandum Decision 20A-JT-894 | October 20, 2020 Page 3 of 16 [6] At a June 2017 permanency hearing, the court found that Mother had partially

enhanced her ability to fulfill her parental obligations, and the court authorized

unsupervised visitation including a trial home visit. In July 2017, while Child

was exercising overnight visitation in Mother’s home, Mother engaged in an

altercation with someone in the home and was thereafter charged with Level 3

felony aggravated battery. Mother was out on bond when she committed that

offense.

[7] On August 28, 2017, Mother was convicted of the August 2016 misdemeanor

battery resulting in bodily injury charge. She was incarcerated in Delaware

County Jail from July 2017 to November 2017. When she was released, she

requested that visits with Child resume, and in November 2017, Mother began

exercising supervised visitation.

[8] At the December 18, 2017 permanency hearing, the court found that Mother

had been incarcerated during a significant portion of the reporting period; she

had not maintained stable housing or a legal source of income; and she was not

compliant with screens before her incarceration and had tested positive for

cocaine. She had recent criminal charges that included an allegation of

aggravated battery, battery resulting in serious bodily injury, possession of

cocaine, and criminal recklessness. The court changed Child’s permanency

plan to adoption with a concurrent plan of reunification.

[9] At a March 2018 review hearing, the court found that Mother was partially

compliant with Child’s case plan. She had taken steps to address anger

Court of Appeals of Indiana | Memorandum Decision 20A-JT-894 | October 20, 2020 Page 4 of 16 management through the Delaware County Probation Department and had

submitted to drug screens but had tested positive for THC and had ongoing

criminal matters. In June 2018, the court continued the concurrent permanency

plan of adoption and reunification. By September 2018, the court authorized

overnight and weekend visits with Mother.

[10] In December 2018, DCS petitioned for a trial home visit but after a December

17, 2018 review hearing, the court denied the request. The court found that

Mother was partially compliant with Child’s case plan, as she was employed,

had stable housing, was cooperative with DCS, and had begun individual

therapy. However, the court concluded that it was not in Child’s best interests

to participate in a trial home visit based on, among other things, the following:

Mother was allowing maternal aunt to provide child care although the court

previously had ordered that the maternal aunt have no visitation with Child;

Mother was driving Child to and from locations without a license and after the

court had admonished her against doing so, noting “the fact that Mother

continues to violate the law and demonstrate poor judgment in transporting the

child on a regular basis is of serious concern to the Court”; she had failed to

appear in city court on five occasions related to her driver’s license; Mother had

“serious” pending criminal charges for Level 3 felony aggravated battery, Level

5 felony battery resulting in serious bodily injury, and Level 6 felony possession

of cocaine; she tested positive for THC in September 2018 and “failed to show

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In the Termination of the Parent-Child Relationship of: K.H. (Minor Child) and M.H. (Mother) v. Indiana Department of Child Services (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-termination-of-the-parent-child-relationship-of-kh-minor-child-indctapp-2020.