Courtney L. Donald a/k/a Courtney Cain v. Z.D.C. b/n/f Shana L. Rhodes (mem. dec.), 45A03-1610-RS-2386

Father (Courtney L. Donald a/k/a Courtney Cain) had paternity and child-support established by a Colorado default judgment in 2006; that Colorado Order was later registered and confirmed in Indiana.
The State filed a petition to confirm the Colorado Order and a contempt citation in Indiana in June 2014; Father was defaulted for failure to appear and an arrearage was reduced to judgment.
After a 2015 arrest on a bench warrant, Father moved under T.R. 60(B) and the parties reached an agreement: the contempt order was vacated, the Colorado Order remained confirmed in Indiana, and the State withdrew the contempt citation.
The State filed a second contempt petition in September 2015; Father then moved to dismiss, arguing the Colorado Order was void for lack of personal jurisdiction because he was never served in Colorado.
The trial court denied the motion to dismiss in September 2016; Father appealed that denial to the Indiana Court of Appeals.
The Court of Appeals concluded the denial was neither a final judgment nor an appealable interlocutory order and dismissed the appeal for lack of appellate subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial-court order denying Father’s motion to dismiss is a final, appealable judgment	State: the confirmation and contempt proceedings remain pending; denial is part of ongoing enforcement	Father: denial resolves his challenge to the foreign judgment’s validity (effectively a T.R. 60(B) collateral attack) and is appealable	Denial is not a final judgment nor an App. R. 14 interlocutory appealable order; appeal dismissed for lack of jurisdiction
Whether Appellate Rule 14 permits immediate interlocutory appeal	State: App. R. 14(A) grounds do not apply	Father: seeks review despite ongoing contempt proceedings	App. R. 14(A) does not authorize appeal here; Father did not meet App. R. 14(B) certification/acceptance requirements
Whether the court could treat Father’s motion as a T.R. 60(B) attack that is appealable	State: T.R. 60(B) rulings are final if styled and decided as such	Father: frames motion as collateral attack on Colorado judgment’s jurisdictional validity	Court noted T.R. 60(B) rulings are final, but Father sought dismissal of the reciprocal action rather than explicit T.R. 60(B) relief; court did not reach merits
Whether the appellate court should reach merits despite jurisdictional defect	State: lack of jurisdiction bars appellate review	Father: urges review to vindicate due-process challenge to foreign judgment	Court declined to reach merits and dismissed for lack of subject-matter jurisdiction

Whittington v. Magnante, 30 N.E.3d 767 (Ind. Ct. App. 2015) (appellate jurisdiction exists only from final judgments except as provided by rule)
Front Row Motors, LLC v. Jones, 5 N.E.3d 753 (Ind. 2014) (final-judgment requirement governs appellate subject-matter jurisdiction)
Georgos v. Jackson, 790 N.E.2d 448 (Ind. 2003) (defining final judgment standard)
In re Estate of Botkins, 970 N.E.2d 164 (Ind. Ct. App. 2012) (court may raise lack of appellate jurisdiction sua sponte; App. R. 14 interlocutory appeal standards)
Bueter v. Brinkman, 776 N.E.2d 910 (Ind. Ct. App. 2002) (final judgment disposes of all claims as to all parties)
Hudson v. Tyson, 383 N.E.2d 66 (Ind. 1978) (longstanding definition of final judgment)
Snyder v. Snyder, 62 N.E.3d 455 (Ind. Ct. App. 2016) (T.R. 54(B) “magic language” can render interlocutory orders final)
Hays v. Hays, 49 N.E.3d 1030 (Ind. Ct. App. 2016) (Indiana courts may inquire into jurisdictional basis for foreign judgments when considering enforcement)
Harry Kaufmann Motorcars, Inc. v. Schumaker Performance, Inc., 964 N.E.2d 872 (Ind. Ct. App. 2012) (applying law of the rendering state in collateral attacks on foreign judgments)