In re the Paternity of Snyder, M.S. v. D.A., 26 N.E.3d 996

Parents: M.S. (Father) and D.A. (Mother) are the parents of M.A., born 2008; Father has lived in Texas during proceedings.
Mother obtained a protective order against Father in March 2012; Father later filed to establish paternity and custody (April 2013).
September 12, 2013 order established support, denied name change, allocated tax claims, and approved therapeutic supervised visitation with therapist Theresa Slayton; protective order was modified to permit visits.
Father sought (June 2014) expanded parenting time, a different therapist, regular Skype contact, and permission to tell M.A. he is her father; court maintained therapeutic supervision, authorized weekly 15-minute supervised Skype calls at the therapist’s office, denied change of therapist, and denied Father’s request to tell M.A. he is her father.
Trial court entered findings; appellate review applied modification standards (abuse of discretion / sufficiency of evidence) for most issues and statutory restriction standard for imposing new limitations on parenting-time communication.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (Mother)	Held
Whether parenting-time restrictions (therapist, frequency, Skype) should be modified	Father asked for more parenting time, a different therapist, regular Skype, and to tell child he is her father	Mother relied on prior agreement/restrictions and therapist concerns about consistency and child stability	Court affirmed most rulings: maintained supervised visits, denied change of therapist, allowed weekly 15-minute supervised Skype at therapist’s office; applied modification standard and found no abuse of discretion in maintaining restrictions
Whether Father may tell M.A. he is her biological father (denial as new restriction)	Father argued statutory parental status exists once paternity is established and there was no evidence that telling the child would harm her	Mother/therapist argued child not ready; therapist suggested withholding title to motivate visitation improvements	Reversed as to this point: trial court erred by denying Father permission to tell M.A. she is his biological father because the record lacked the statutorily required finding that such disclosure would endanger physical health or significantly impair emotional development

Speaker v. Speaker, 759 N.E.2d 1174 (App. Ct. Ind.) (standard for reviewing findings and judgment on appeal)
Speed v. Old Fort Supply Co., Inc., 737 N.E.2d 1217 (App. Ct. Ind.) (appellate court will not reweigh evidence or reassess witness credibility)
Myers v. Leedy, 915 N.E.2d 133 (Ind.) (review of general judgments where trial court sua sponte entered findings)
Julie C. v. Andrew C., 924 N.E.2d 1249 (App. Ct. Ind.) (custody-modification standard and burden on petitioner to show change)
Hatmaker v. Hatmaker, 998 N.E.2d 758 (App. Ct. Ind.) (parenting-time restrictions reviewed for abuse of discretion; goal of fostering relationship with each parent)
In re Paternity of T.M., 953 N.E.2d 96 (App. Ct. Ind.) (paternity, and limits on disestablishing paternity absent fraud, duress, or material mistake)
Farrell v. Littell, 790 N.E.2d 612 (App. Ct. Ind.) (statute requires specific finding of physical endangerment or emotional impairment before imposing parenting-time restrictions)