In Re the Matter of Patricia Rumfelt v. Alicia Hollars and Harry Arndt (mem. dec.), 20A03-1703-MI-536

Patricia Rumfelt (paternal grandmother) filed for grandparent visitation for A.A. (the child) after Mother curtailed contact with paternal family following medical treatment and disputes involving the child’s paternal great-aunt.
A guardian ad litem (GAL) reported the father had little contact for years, the great-aunt initiated the petition in Rumfelt’s name, and the child associated the paternal family primarily with the great-aunt.
Evidence showed Rumfelt had intermittent contact over the years but was not the primary caregiver; the great-aunt and paternal great-grandmother spent substantially more time with the child.
Mother removed or limited contact after the great-aunt allegedly interfered with the child’s medical care, texted the child that Mother was not caring for her, and told the child she would take Mother to court; the child resented the great-aunt and did not want contact.
The trial court denied Rumfelt’s petition, finding Mother is a fit parent, the child does not want contact now, the petition was largely driven by the great-aunt, and visitation was not shown to be in the child’s best interests.
Rumfelt appealed the denial; Mother sought appellate attorney fees, which the court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying grandparent visitation	Rumfelt: She had a meaningful relationship and was entitled to visitation; great-aunt’s role shouldn’t bar her claim	Mother: Child has no significant relationship with Rumfelt; Mother is a fit parent and restricted contact to protect child after great-aunt’s interference; adoption/termination of father’s rights affects status	Court affirmed: No abuse of discretion — evidence supports finding Mother is fit, child opposes contact, petition not shown to be in child’s best interests

In re Visitation of K.M., 42 N.E.3d 572 (Ind. Ct. App. 2015) (standard for trial-court findings and consideration whether grandparent attempted meaningful contact)
In re Visitation of L-A.D.W., 38 N.E.3d 993 (Ind. 2015) (deference to trial courts in family law matters)
In re Visitation of M.L.B., 983 N.E.2d 583 (Ind. 2013) (framework protecting fit parents’ constitutional right to direct child-rearing and required factors for grandparent visitation)
Wilder-Newland v. Kessinger, 967 N.E.2d 558 (Ind. Ct. App. 2012) (appellant of a negative family-law judgment must show the evidence unerringly supports a different conclusion)
Thacker v. Wentzel, 797 N.E.2d 342 (Ind. Ct. App. 2003) (standards for awarding appellate attorney fees for frivolous or bad-faith appeals)