In the Matter of J.C. and R.C. (Minor Children) B.C. (Mother) v. Indiana Department of Child Services, and Child Advocates, Inc., 142 N.E.3d 427

Mother (B.C.) is biological parent of two children; DCS filed termination petitions in March 2018.
Statute requires a TPR hearing to commence within 90 days and be completed within 180 days of filing; failure to complete allows dismissal on motion.
At a June 25, 2018 pretrial the court scheduled hearing dates (Sept. 26 and Oct. 10) and the order stated, “Parties waive the 180 day requirement.” Mother’s counsel did not object to the setting.
The hearing began Sept. 26 and was continued at Mother’s counsel’s request; additional sessions occurred Oct. 10–11. Mother made an oral motion to dismiss on Oct. 11 for exceeding 180 days; the court denied it.
Mother later agreed to continue the remaining testimony to Nov. 26, 2018; the evidentiary hearing concluded then (more than 180 days after filing). The trial court terminated Mother’s parental rights in Jan. 2019.
The Court of Appeals affirmed. The Indiana Supreme Court granted transfer limited to whether dismissal was required for exceeding the 180-day deadline and affirmed, holding Mother waived the deadline and invited any error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court erred by denying Mother’s motion to dismiss because the TPR hearing was not completed within 180 days	Mother: statutory 180-day limit is mandatory; failure to complete requires dismissal	DCS: Mother waived the 180-day requirement and later agreed to continuances; invited error doctrine bars relief	Court: No reversible error — Mother affirmatively waived the 180-day rule and invited any error, so dismissal was not required
Admissibility of drug-screen reports	Mother: drug-screen reports should not be admitted	DCS: reports admissible	Court of Appeals: no reversible error; Supreme Court summarily affirmed
Sufficiency of evidence to terminate parental rights	Mother: evidence insufficient for TPR	DCS: sufficient evidence supports termination	Court of Appeals: evidence sufficient; Supreme Court summarily affirmed

Rodriguez v. State, 129 N.E.3d 789 (Ind. 2019) (statutory interpretation reviewed de novo)
Durden v. State, 99 N.E.3d 645 (Ind. 2018) (invited-error doctrine explained)
Witte v. Mundy ex rel. Mundy, 820 N.E.2d 128 (Ind. 2005) (party cannot benefit from error it invited)
Booher v. State, 773 N.E.2d 814 (Ind. 2002) (invited error is not reversible error)
In re J.R., 98 N.E.3d 652 (Ind. Ct. App. 2018) (CHINS 60-day deadline; held mandatory where parties did not consent to extension)
In re T.T., 110 N.E.3d 441 (Ind. Ct. App. 2018) (CHINS deadline cannot be extended by parties where statute disallows it)
In re M.S., 140 N.E.3d 279 (Ind. 2020) (addresses CHINS deadlines and Trial Rule 53.5 good-cause continuances)
C.T. v. Marion Cty. Dep't of Child Servs., 896 N.E.2d 571 (Ind. Ct. App. 2008) (invited-error applied in child-welfare context)
In re N.C., 83 N.E.3d 1265 (Ind. Ct. App. 2017) (parent who agreed to late hearing date could not later challenge timing)
In re J.C., 134 N.E.3d 419 (Ind. Ct. App. 2019) (Court of Appeals opinion below affirming on waiver/invited-error grounds)