In the Matter of: L.C. (Minor Child), Child in Need of Services and S.C. (Father) v. The Indiana Department of Child Services, 23 N.E.3d 37

Father (S.C.) had full custody of minor L.C.; child later lived with Mother and was present during a domestic violence incident in which Mother was intoxicated. DCS filed a CHINS petition and removed L.C. to therapeutic foster care.
Mother admitted the CHINS allegations; Father denied them and requested a contested fact-finding hearing.
The juvenile court announced at the start of the fact-finding hearing that it would accept Mother’s admission and adjudicate L.C. a CHINS; the court issued an interim order finding removal was in L.C.’s best interests before Father’s fact-finding hearing concluded.
Additional evidence was heard on two days (April 8 and April 14); the court later continued the adjudication at disposition, granted DCS wardship, ordered reunification services for Father, and placed L.C. in a conditional in-home trial with Father.
Father appealed, arguing due process violation because the court adjudicated L.C. a CHINS before completing Father’s fact-finding hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether adjudicating child a CHINS before completing a contesting parent’s fact-finding hearing violated due process	Father: court deprived him of a meaningful CHINS hearing by adjudicating L.C. before his hearing concluded	DCS: prior admission by Mother and subsequent proceedings gave Father full procedural protections; he was not denied meaningful process	Court: Reversed — adjudication before completion of Father’s fact-finding hearing violated due process; remand for new fact-finding hearing
Whether a CHINS adjudication requires separate analysis for each parent when one admits and one contests	Father: contesting parent must be allowed full fact-finding so adjudication isn’t foreclosed by other parent’s admission	DCS: admission by one parent can support adjudication; later contested dispositional proceedings suffice	Court: Where one parent contests, the court must reserve judgment and complete the contesting parent’s fact-finding before adjudicating the child a CHINS

In re N.E., 919 N.E.2d 102 (Ind. 2010) (CHINS adjudication determines child’s status, not parental culpability)
S.S. v. Ind. Dep’t of Child Servs. (In re K.D.), 962 N.E.2d 1249 (Ind. 2012) (when one parent admits and another contests, court must reserve adjudication until completion of contesting parent’s fact-finding)
In re T.N., 963 N.E.2d 467 (Ind. 2012) (due process requires fact-finding hearing when one parent admits and another denies)
In re G.P., 4 N.E.3d 1158 (Ind. 2014) (articulates the Mathews balancing test and the importance of due process at all CHINS stages)
In re V.C., 967 N.E.2d 50 (Ind. Ct. App. 2012) (parents’ procedural rights during CHINS fact-finding: cross-examination, compulsory process, and presenting evidence)
D.H. v. Marion County Office of Family & Children, 859 N.E.2d 737 (Ind. Ct. App. 2007) (speculation insufficient to support CHINS finding)
Thompson v. State, 804 N.E.2d 1146 (Ind. 2004) (appellate courts do not reweigh evidence or assess witness credibility)