Larracuenta R. Panfil v. Ralph E. Fell, 19 N.E.3d 772

Parents divorced in 2004; dissolution incorporated settlement requiring Daughter to pay one-third of college costs and parents to share remaining two-thirds equally.
In 2012 the trial court conditioned Father’s obligation to pay post-secondary expenses on Daughter maintaining a 2.1 GPA and not being placed on probation or disciplined for school rule violations.
In Fall 2013 Daughter received an F in an online history course after admitting she plagiarized student peer-review comments; the instructor failed her instead of referring the matter to the Dean of Students.
Father petitioned (Jan. 2014) to discontinue paying Daughter’s college expenses based on the 2012 condition; after a hearing the court (Feb. 7, 2014) terminated Father’s obligation, finding the F constituted a disciplinary action.
Mother’s motion to correct errors sought reversal/clarification (including whether termination was retroactive); the court denied the motion and clarified Father’s obligation ended with fall 2013 costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred/abused discretion in terminating Father’s obligation to pay post-secondary expenses and denying Mother’s motion to correct errors	Mother: The F was not a disciplinary action under Purdue rules; relieving Father is punitive and inconsistent with educational support purposes	Father: The F was a punitive grade (disciplinary action) under Purdue guidance; trial court properly enforced its 2012 conditional support order and may set minimal behavioral standards	Court: Affirmed — the instructor’s punitive grading for plagiarism constituted the disciplinary action contemplated by the 2012 order; termination of Father’s obligation (ending with fall 2013 semester) was not an abuse of discretion

Ind. Bureau of Motor Vehicles v. Charles, 919 N.E.2d 114 (Ind. Ct. App. 2009) (motions to correct error reviewed for abuse of discretion)
Speedway SuperAmerica, LLC v. Holmes, 885 N.E.2d 1265 (Ind. 2008) (abuse of discretion standard explained)
Lea v. Lea, 691 N.E.2d 1214 (Ind. 1998) (deference to trial court on child support modifications)
Quillen v. Quillen, 671 N.E.2d 98 (Ind. 1996) (findings clearly erroneous only if record lacks supporting facts)
Menard, Inc. v. Dage-MTI, Inc., 726 N.E.2d 1206 (Ind. 2000) (judgment erroneous if based on incorrect legal standard)
Yoon v. Yoon, 711 N.E.2d 1265 (Ind. 1999) (appellate deference to credibility findings)
Knisely v. Forte, 875 N.E.2d 335 (Ind. Ct. App. 2007) (educational expenses distinct from child support)
Sutton v. Sutton, 773 N.E.2d 289 (Ind. Ct. App. 2002) (same)
Gilbert v. Gilbert, 777 N.E.2d 785 (Ind. Ct. App. 2002) (court may order parental contribution to college costs)
Deckard v. Deckard, 841 N.E.2d 194 (Ind. Ct. App. 2006) (trial courts encouraged to set minimum academic standards)
Schacht v. Schacht, 892 N.E.2d 1271 (Ind. Ct. App. 2008) (college expense orders are modifiable)
Walters v. Walters, 901 N.E.2d 508 (Ind. Ct. App. 2009) (support orders, including post-secondary, may be modified despite prior agreements)
Meehan v. Meehan, 425 N.E.2d 157 (Ind. 1981) (modification principles for agreed support orders)