N.E. v. Indiana Department of Child Services, 5 N.E.3d 786

DCS seeks to terminate parental rights for CHINS children in Lake County, with adoption pending despite ongoing CHINS/TPR proceedings.
N.E., the children's former foster parent, petitioned to intervene in CHINS but was denied and later filed petitions to adopt in Lake Superior Court.
DCS and CASA filed motions to intervene or transfer the adoption to Juvenile Court; Superior Court denied these motions.
DCS argues Caseload Allocation Plan requires adoption cases to be filed in Juvenile Court, conflicting with probate jurisdiction.
The issue presented is whether Lake County Civil Division, which houses probate jurisdiction, has exclusive authority over adoptions, or if Caseload Plan diverts it to Juvenile Court.
The Indiana Supreme Court previously held Lake County Juvenile Division lacks probate jurisdiction over adoptions; the Caseload Plan attempts to reallocate but conflicts with statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Caseload Plan vs. probate exclusive jurisdiction	DCS: plan overrides probate rules to transfer adoptions	N.E.: probate jurisdiction is exclusive; plan cannot trump it	Plan cannot trump; probate exclusive jurisdiction remains
Venue for adoption proceedings in Lake County	DCS: adoption cases must be in Juvenile Court per plan	N.E.: probate court retains exclusive jurisdiction under statute	Superior Court properly denied transfer; no jurisdictional shift

In re Infant Girl W., 845 N.E.2d 229 (Ind.Ct.App. 2006) (probate has exclusive jurisdiction over adoption; concurrent CHINS/TPR exists)
Matter of Adoption of T.B., 622 N.E.2d 921 (Ind. 1993) (Lake County Juvenile cannot assert probate-adoption jurisdiction; concurrent probate matters)
Pera, 987 N.E.2d 1074 (Ind. 2013) (local Caseload Allocation Plan not a Supreme Court rule; cannot override statute)
Georgetown Bd. of Zoning Appeals v. Keele, 743 N.E.2d 301 (Ind.Ct.App. 2001) (subject matter jurisdiction arises from constitution or statutes)