In Re The Matter of S.G. (Minor Child) P.G. (Mother) v. The Indiana Department of Child Services (mem. dec.), 49A05-1610-JC-2351

Mother, a 16-year-old who had previously been adjudicated CHINS and discharged from a court-ordered residential treatment program, gave birth to S.G. in January 2016.
S.G. was placed in foster care five days after birth because Mother could not take the child to Valle Vista and grandparents could not assume placement due to prior DCS involvement.
Mother had only supervised visitation, had never been alone with S.G., and began shortening longer visits because she became tired or distracted.
Concerns about the proposed home environment included grandparents with serious health issues (one on oxygen), household members who smoked in the home, a recent bed-bug infestation, missing recommended safety items (e.g., safety gates), persons with outstanding DCS issues, and incomplete background checks for household members.
DCS petitioned to adjudicate S.G. as a CHINS, arguing Mother lacked ability, financial means, and parenting skills to provide a safe environment and that court intervention was necessary for the child’s care.
The trial court found S.G. to be a CHINS; Mother appealed claiming insufficient evidence for (1) serious impairment/endangerment due to parental neglect and (2) need for court coercion to obtain care.

Issue	Plaintiff's Argument (DCS)	Defendant's Argument (Mother)	Held
Whether there was sufficient evidence to adjudicate S.G. a CHINS under Ind. Code § 31-34-1-1 (serious impairment/endangerment and need for court intervention)	Evidence showed Mother lacked supervision ability, had never been alone with the infant, shortened visits, and the home had multiple safety risks — so the child was endangered and needs court-ordered services	DCS failed to prove by a preponderance that S.G. was seriously endangered or that care/treatment would be unavailable without court coercion	Affirmed: evidence supported findings that S.G. was seriously endangered by lack of supervision and that coercive intervention was necessary for the child’s care

In re S.D., 2 N.E.3d 1283 (Ind. 2014) (standard for reviewing sufficiency of evidence in CHINS matters)
In re A.G., 6 N.E.3d 952 (Ind. Ct. App. 2014) (two-tiered review when trial court issues findings and conclusions)
E.P. v. Marion Cty. Office of Family and Children, 653 N.E.2d 1026 (Ind. Ct. App. 1995) (parental rights are constitutionally protected but subject to state interest in child welfare)
In re N.E., 919 N.E.2d 102 (Ind. 2010) (CHINS proceedings are civil and require proof by preponderance; focus is child’s condition not parental culpability)