B.L. v. J.S., 59 N.E.3d 253

Mother and Father divorced; Mother awarded primary physical custody and parties shared joint legal custody of their daughter, K.L.; parenting time governed by Indiana Parenting Time Guidelines with specific weekday and weekend allocations.
Post-decree, parties repeatedly litigated parenting-time disputes; multiple contempt petitions and interim orders adjusted Father’s midweek parenting time and pickup permissions.
Mother sought to relocate from a rural property to Fishers (20–25 minutes from Father); she testified the move was for practical reasons (closer to work, activities, neighborhood environment) and not to thwart Father’s relationship.
Trial court found Mother’s relocation in good faith and for legitimate reasons, shifted burden to Father to show relocation was not in the child’s best interest, and rejected Father’s objection.
Trial court also ordered the child to attend a YMCA after-school enrichment program during certain midweek periods rather than granting Father additional parenting time, finding the program benefited the child (exercise, socialization, homework help).
Father was found in contempt for repeatedly picking up the child from school outside his designated parenting times in violation of a clear June 26, 2014 order; the court affirmed contempt based on willful disobedience of the order.

Issue	Father’s Argument	Mother’s Argument	Held
Whether trial court abused discretion in allowing Mother to relocate	Mother’s stated reasons were pretextual; relocation would lengthen Mother’s commute and was unnecessary	Relocation was in good faith for legitimate, practical reasons (work, activities, neighborhood) and minimally affected Father	Affirmed: Court found relocation in good faith and Father failed to show it was against child’s best interest
Whether trial court abused discretion by not granting Father additional parenting time (instead requiring YMCA attendance)	Court improperly prioritized third-party childcare over a fit parent; Guidelines presume parental care preferable	YMCA program provides exercise, socialization, homework help; deviation explained as in child’s best interest	Affirmed: Court did not abuse discretion in requiring the child attend the after-school program rather than awarding extra parenting time
Whether trial court abused discretion by holding Father in contempt	Father contended prior orders/Agreed Entry permitted pickups; he disputed that he violated a clear order	Mother argued Father willfully removed child from school before his scheduled parenting time, violating June 26th Order	Affirmed: Contempt upheld — June 26th Order was clear and Father willfully violated it

In re Paternity of C.S., 964 N.E.2d 879 (Ind. Ct. App.) (standard for reviewing findings and judgment under T.R. 52)
D.C. v. J.A.C., 977 N.E.2d 951 (Ind.) (deference to trial courts in family law and credibility assessments)
Best v. Best, 941 N.E.2d 499 (Ind.) (family-law deference to trial court determinations)
T.L. v. J.L., 950 N.E.2d 779 (Ind. Ct. App.) (standards for relocation: burden and legitimate/good-faith reasons)
Gilbert v. Gilbert, 7 N.E.3d 316 (Ind. Ct. App.) (relocating parent’s reasons must be more than mere pretext)
Shelton v. Shelton, 835 N.E.2d 513 (Ind. Ct. App.) (presumption favoring parental childcare; Guidelines may be deviated from with explanation)
City of Gary v. Major, 822 N.E.2d 165 (Ind.) (willful disobedience required for civil contempt)
Ind. High Sch. Athletic Ass’n v. Martin, 765 N.E.2d 1238 (Ind.) (order must be clear and certain to support contempt)