In the Termination of the Parent-Child Relationship of: J.P. and R.P. (Minor Children), and, N.P. (Mother) v. The Indiana Department of Child Services (mem. dec.), 49A02-1603-JT-666

Mother (N.P.) has three children; J.P. (b.2008) and R.P. (b.2011) are subjects of this appeal; earlier CHINS finding and a 2013 criminal conviction for neglect related to alleged choking of J.P.
After a 2011 CHINS case (children removed May 2011–July 2013) and completion of services, a new CHINS petition was filed in Jan. 2014 alleging domestic violence; children were removed again and Mother initially cooperated.
In mid-2014 Mother fled for six months with another child, did not participate in services, used methamphetamine, and later was convicted on related charges; she is incarcerated with earliest release Jan. 2017.
DCS filed a petition to terminate Mother’s parental rights to J.P. and R.P. on June 29, 2015; at the fact‑finding hearing DCS offered 15 certified CHINS-related exhibits and Mother’s counsel stated no objection to admission but requested the court be mindful of hearsay within them.
The trial court admitted the exhibits and misstated that hearsay rules do not apply in termination proceedings; it later entered an order terminating Mother’s parental rights on March 7, 2016.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court improperly relied on hearsay in ruling on the termination petition	Mother argued the termination decision relied on inadmissible hearsay in DCS exhibits	DCS argued the exhibits were certified court documents and contained admissible material and that Mother’s counsel effectively assented to admission; hearsay exceptions (public/business records) may apply	Court affirmed: Mother waived the claim by failing to specify objections at trial and failed to show any error affected her substantial rights; any misstatement about hearsay rules was not reversible error

Raess v. Doescher, 883 N.E.2d 790 (Ind. 2008) (contemporaneous objection must specify grounds to preserve evidentiary claim)
Robey v. State, 7 N.E.3d 371 (Ind. Ct. App. 2014) (party may not acquiesce to evidence then complain on appeal)
D.B.M. v. Indiana Dep’t of Child Servs., 20 N.E.3d 174 (Ind. Ct. App. 2014) (hearsay rules and business/public records exceptions in termination proceedings)
B.H. v. Indiana Dep’t of Child Servs., 989 N.E.2d 355 (Ind. Ct. App. 2013) (not all evidentiary error in termination cases is reversible; harmless-error standard)
N.C. v. Indiana Dep’t of Child Servs., 56 N.E.3d 65 (Ind. Ct. App. 2016) (appellate waiver for failure to make cogent argument and cite record)