In the Matter of L.G., A Child in Need of Services, J.C., Father v. Indiana Department of Child Services (mem. dec.), 52A05-1610-JC-2454

Sixteen-year-old L.G. had a prior CHINS case (Aug 2014–late 2015/early 2016) and was placed with his father (J.C.) after that case closed. Father worked third shift and arranged for the child to be supervised at the aunt’s home.
On June 14, 2016 police discovered a methamphetamine lab at the aunt’s home; L.G. tested positive for methamphetamine and marijuana and told DCS he knew of the illegal activity and used drugs.
Father was at the hospital, denied knowledge of the child’s drug use, and indicated he could not take the child home that night because of work; DCS detained the child and placed him at Youth Opportunity Center (YOC).
Father admitted difficulty managing the child, had stopped taking the child to an outpatient provider (Four County) because the provider allegedly failed to give medications, and acknowledged the child missed several weeks of school while off medication.
The child ran away from YOC in July 2016; by the August fact-finding hearing he remained missing. The juvenile court adjudicated the child a CHINS and ordered placement with DCS; dispositional findings emphasized the child’s substance use, missed medications, school absences, need for intensive treatment, and the father’s limited supervision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence sufficed to adjudicate L.G. a CHINS under I.C. § 31‑34‑1‑1 (father’s actions/inactions seriously endangered the child)	DCS: evidence (meth lab at aunt’s, positive drug tests, child’s disclosure, father left child at aunt’s, father not providing needed supervision/services) proves endangerment and unmet needs unlikely to be remedied without court intervention	Father: he believed aunt’s home was safe, he did not know of illegal activity or the child’s drug use, and his prior cessation of services was reasonable because the provider failed to medicate the child	Court affirmed: evidence supported findings that father’s inability/neglect endangered the child and that coercive intervention was necessary
Whether specific findings that father failed to provide services/medications and that school absences resulted from father’s actions were supported	DCS: father stopped services, child was off meds, and missing school followed from lack of medication and supervision	Father: no legal obligation to continue services after prior CHINS closed and DCS failed to show his actions caused school absences	Court held findings 8 and 10 were supported by the evidence (father quit provider, child off meds, missed school), so they supported the CHINS adjudication

In re L.C., 23 N.E.3d 37 (Ind. Ct. App. 2015) (standards for CHINS burden and review)
In re N.E., 919 N.E.2d 102 (Ind. 2010) (CHINS elements and focus on child protection over parental fault)
In re A.G., 6 N.E.3d 952 (Ind. Ct. App. 2014) (two‑tiered review when trial court issues findings and conclusions)
In re T.S., 906 N.E.2d 801 (Ind. 2009) (appellate review principles for juvenile cases)
In re V.H., 967 N.E.2d 1066 (Ind. Ct. App. 2012) (deference to trial court findings but not conclusions)
In re S.D., 2 N.E.3d 1283 (Ind. Ct. App. 2014) (explaining the three basic elements of CHINS statutory definition)
In re K.D., 962 N.E.2d 1249 (Ind. 2012) (CHINS purpose: protect children, not punish parents)
In re A.H., 913 N.E.2d 303 (Ind. Ct. App. 2009) (courts need not wait for tragedy before intervening in CHINS cases)
In re B.R., 875 N.E.2d 369 (Ind. Ct. App. 2007) (unchallenged trial court findings stand as proven)