In Re the Marriage of: Angela R. Bello v. Clement A. Bello, 102 N.E.3d 891

Angela Bello (Mother) and Clement Bello (Father) divorced in 2010; Mother received sole physical custody of their son K.B. and the parties shared legal custody.
The dissolution decree was silent on extracurricular activities; Father had scheduled parenting time including weekly overnights and alternating weekends.
Father moved in 2016 and again in 2017 alleging Mother repeatedly enrolled K.B. in multiple overlapping extracurriculars, reducing Father’s parenting time and usurping joint decision-making.
The court’s June 28, 2016 order limited K.B. to one sport and one other activity per season and required joint decision-making; the August 11, 2017 order found Mother in contempt for continuing to overschedule K.B., ordered termination of non-school activities absent written agreement, awarded make-up parenting time, and directed attorney fees.
The court entered a September 1, 2017 order requiring Mother to pay $2,500 toward Father’s attorney fees; Mother filed a T.R. 60(B)/(C) motion for relief which the trial court summarily denied on October 3, 2017.
On appeal Mother challenged the denial of her T.R. 60(B) motion but did not identify any specific T.R. 60(B) ground or develop arguments on those grounds; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Mother’s T.R. 60(B) motion for relief from the contempt/order and attorney-fee award	Mother argued the judgment should be set aside because the court failed to consider Father’s alleged intentional absence from parenting time and his improper motives (but did not cite a specific T.R. 60(B) ground)	Father defended the contempt/order as supported by findings that Mother continued to overschedule the child in violation of the prior order and that attorney fees were warranted	Court affirmed: Mother failed to invoke or argue any specific T.R. 60(B) ground and cannot use T.R. 60(B) as a substitute for direct appeal; denial was not an abuse of discretion

Laflamme v. Goodwin, 911 N.E.2d 660 (Ind. Ct. App. 2009) (T.R. 60(B) provides avenue for relief from final judgment)
Indiana Ins. Co. v. Ins. Co. of N. Am., 734 N.E.2d 276 (Ind. Ct. App. 2000) (trial court must balance movant’s injustice against finality interests; T.R. 60(B) standards)
Brimhall v. Brewster, 864 N.E.2d 1148 (Ind. Ct. App. 2007) (T.R. 60(B) motions addressed to equitable discretion; abuse of discretion standard)
Snider v. Gaddis, 413 N.E.2d 322 (Ind. Ct. App. 1980) (T.R. 60(B) not a substitute for direct appeal or to revive an expired appeal)