In Re: The Matter of Joyce Hall Incapacitated Adult, Barbara Rich and Donald Rich v. Imogene Suzann Fischman (mem. dec.), 30A01-1605-GU-1155

Barbara and Donald Rich served as co-guardians of their sister Joyce Hall from April 2007 until June 2015 and controlled her finances while she lived in various residences.
Fischman, another sister, moved to terminate the guardianship in Sept. 2014, requested a detailed accounting, and was appointed temporary guardian of the estate in June 2015 after the Riches failed to provide adequate records.
The Riches filed a lengthy but undocumented accounting showing deposits and expenditures nearly in balance; the trial court found it lacked dates, receipts, and other verification required by statute.
At evidentiary hearings Fischman presented testimony documenting numerous unexplained or excessive expenditures and unpaid medical bills; the Riches produced bank statements only after court order.
The trial court concluded the Riches failed to meet fiduciary/accounting duties and ordered them to repay $45,817.46 to Hall’s estate, to pay $300/month, and authorized a lien and changes to funeral trust beneficiaries.
The Riches appealed, arguing statutory and evidentiary errors; the Court of Appeals affirmed the reimbursement order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly ordered the Riches to repay $45,817.46 to the estate	Fischman: Riches failed to document expenditures and must reimburse the estate for misapplied funds	Riches: Their submitted records were reasonable under the circumstances and the court erred in ordering reimbursement	Affirmed: Court found lack of required documentation, fiduciary breach, and evidence supporting repayment order
Whether trial court erred by not explicitly ordering inventories/biennial accountings or setting reporting standards	Riches: Court should have individually ordered recordkeeping and set standards under I.C. §29-3-9-6.5	Fischman: Guardianship statutes already require inventories/accountings; Riches waived reliance on §29-3-9-6.5 and did not raise it below	Affirmed: Argument waived and statutory duties existed independent of §6.5; no reversible error
Whether the findings were clearly erroneous	Riches: Findings lack support; court applied wrong standard	Fischman: Findings supported by testimony and documents produced; standard properly applied	Affirmed: Findings supported by evidence and not clearly erroneous
Whether any relief other than reimbursement was warranted (e.g., contempt/sanctions)	Fischman: Additional sanctions appropriate for failure to comply	Riches: (implicit) relief excessive	Court imposed repayment, monthly payments, and lien authority; contempt/sanctions not detailed on appeal

In re Guardianship of Stalker, 953 N.E.2d 1094 (Ind. Ct. App. 2011) (guardians’ fiduciary duties derive from statute)
Wells v. Guardianship of Wells, 731 N.E.2d 1047 (Ind. Ct. App. 2000) (guardian must manage estate in ward’s best interest; entitled to reasonable compensation and reimbursement for reasonable, good-faith expenditures)
Yanoff v. Muncy, 688 N.E.2d 1259 (Ind. 1997) (standards for appellate review of findings and general judgments)