In the Matter of R.J., A Minor Child, A Child in Need Of Services, S.E. v. The Indiana Department of Child Servcies (mem. dec.), 49A05-1702-JC-246

DCS filed a CHINS petition in March 2014 concerning R.J. (born 2006); R.J. was removed from Mother's home and placed with a maternal aunt. Father was later identified via DNA as R.J.'s biological father.
Father lived in Ohio, had intermittent contact with DCS, and initially waived a factfinding hearing; the court entered dispositional and parental participation orders requiring cooperation with ICPC.
Over 2014–2016, progress reports documented periods when Father was unreachable, mixed engagement with services, admissions of daily marijuana use in 2016 parenting/psychological assessments, and recommendations for mental‑health, substance‑use, anger‑management, and therapeutic‑visitation services.
DCS changed R.J.’s permanency plan to adoption in May 2015; Father later expressed interest in reunification and completed a parenting assessment that produced recommended services.
In December 2016 DCS moved to modify the dispositional decree to require specific services (random drug screens, psychiatric evaluation, anger management, individual therapy, releases for records, weekly contact with the case manager).
The juvenile court granted the modification in January 2017; Father appealed, arguing the court relied on no admissible evidence at the modification hearing.

Issue	Father’s Argument	DCS’s Argument	Held
Whether the trial court’s modification of the dispositional decree was clearly erroneous	No admissible evidence was presented at the modification hearing to support the new parental participation requirements; modification was untimely and procedurally deficient	Modification hearing may consider dispositional/progress/modification reports and hearsay; ordered services were supported by DCS reports, assessments, ICPC noncompliance, and R.J.’s exposure history	Affirmed: findings supported by DCS modification and progress reports and witness statements; hearsay/progress reports admissible in dispositional/modification context

In re T.S., 906 N.E.2d 801 (Ind. 2009) (standard of review and procedures for modification hearings and reports)
In re A.C., 905 N.E.2d 456 (Ind. Ct. App. 2009) (parental participation orders must relate to behaviors shown by the evidence)
In re K.D., 962 N.E.2d 1249 (Ind. 2012) (dispositional hearings may admit hearsay and DCS reports)
N.L. v. State, 989 N.E.2d 773 (Ind. 2013) (hearsay admissible in dispositional/modification hearings to avoid excluding relevant child‑welfare information)