In the Matter of: S.A. (Minor Child), Child in Need of Services and M.H. (Father) v. The Indiana Department of Child Services, 15 N.E.3d 602

Father M.H. appeals a trial court order continuing the Child S.A.’s CHINS adjudication.
Mother admitted CHINS-allegations; paternity later established for Father via DNA testing.
Child lived with Grandmother; Father had minimal prior contact and no child support.
DCS alleged CHINS due to Mother's drug use and Father’s unknown whereabouts, plus parenting concerns.
Father subsequently participated in paternity testing, moved to Indianapolis, and began interactions with the Child.
The trial court continued CHINS status, ordered parenting assessments, and considered PTSD treatment as part of concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CHINS adjudication was proper	Father argues no evidence of serious impairment or need for coercive court intervention.	DCS argues ongoing risks due to parenting history and PTSD justify CHINS.	CHINS adjudication reversed; proceedings improper

In re S.D., 2 N.E.3d 1283 (Ind. 2014) (two-tier review; CHINS requires proper factual support)
In re N.E., 919 N.E.2d 102 (Ind. 2010) (per-parent approach; due process concerns when adjudicating multiple parents)
In re K.D., 962 N.E.2d 1253 (Ind. Ct. App. 2012) (separate analysis may be required when both parents implicated)
In re T.N., 963 N.E.2d 467 (Ind. 2012) (CHINS may interfere with parental rights; need careful statutory compliance)
In re R.S., 987 N.E.2d 155 (Ind. Ct. App. 2013) (consider child’s status at time of fact-finding; avoid reliance on outdated conditions)