Janet L. McDaniel v. Mark L. McDaniel (mem. dec.), 45A03-1511-DR-1934

Janet (Mother) and Mark McDaniel (Father) divorced after a 2008 settlement providing joint custody, Mother to maintain children’s life insurance in lieu of paying child support.\
Post-dissolution litigation escalated: 2012 orders required counseling and $29/week child support; Mother was told to continue life insurance policies.\
Father filed multiple rule-to-show-cause petitions alleging Mother missed child support, cancelled life insurance by using cash value to pay premiums, failed to timely file relocation notice, interfered with counseling, denied parenting time, and failed to contribute to medical/extracurricular costs.\
Mother filed petitions to relocate, to modify parenting time and child support (claiming she would provide health insurance), and sought in-camera interviews of the children.\
After hearings, the trial court found Mother in contempt for several willful violations (insurance premium payments, counseling conduct, Christmas parenting time), denied Mother’s modification requests (school and parenting-time changes and child-support modification), awarded Father $2,500 in attorney fees, and admitted but said it would not consider a prejudicial email. Mother appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether two specific findings lacked evidentiary support	Mother: findings that mediation was "extensive" and that she was unaware of her deductible are unsupported	Father: those findings are immaterial to the judgment	Court: even if unsupported, findings were not prejudicial and do not require reversal
2. Whether Mother was properly found in contempt	Mother: failures (insurance payments, counseling demeanor, delayed counselor selection) were mistakes or justified, not willful disobedience	Father: evidence shows deliberate refusal to comply and hostile counseling conduct	Court: contempt findings upheld as supported by evidence and not an abuse of discretion
3. Whether child support modification should have been granted	Mother: by providing health insurance ($35.70/wk) she altered support obligations and warranted modification	Father: Mother did not prove changed circumstances; policies not shown comparable; reimbursement history weak	Court: modification denied—Mother failed her burden to show substantial, continuing change
4. Whether trial court erred admitting an email from Mother’s ex-husband	Mother: the email was hearsay and prejudicial	Father: admitted as evidence of family dynamics; trial court said it would not consider it	Court: any error harmless because court stated it would not consider the email

Old Utica School Preservation, Inc. v. Utica Tp., 7 N.E.3d 327 (Ind. Ct. App. 2014) (standard for reviewing motion to correct error/abuse of discretion)\
Argonaut Ins. Co. v. Jones, 953 N.E.2d 608 (Ind. Ct. App. 2011) (effect of sua sponte findings on appellate review)\
Barkwill v. Cornelia H. Barkwill Revocable Trust, 902 N.E.2d 836 (Ind. Ct. App. 2009) (two-tiered review of sua sponte findings and conclusions)\
Ghosh v. Ghosh, 26 N.E.3d 986 (Ind. Ct. App. 2015) (clear-error standard for findings of fact)\
Stone v. Stone, 991 N.E.2d 992 (Ind. Ct. App. 2013) (deference to trial court in family law matters)\
Miller v. Carpenter, 965 N.E.2d 104 (Ind. Ct. App. 2012) (standard for reviewing child-support modification)\
Davis v. Garrett, 887 N.E.2d 942 (Ind. 2008) (trial court discretion on evidence admissibility and harmless-error rule)