R.K. v. Indiana Department of Child Services, 964 N.E.2d 240

Mother and Father, residents of Baltimore, relocated to Fort Wayne in January 2011 with their three minor children after a series of hardships.
DCS filed a CHINS petition alleging the parents failed to provide shelter and basic necessities for the Children.
A dispositional hearing followed, culminating in a CHINS designation based on findings of fact and conclusions on the record.
The trial court found that Mother relocated to Fort Wayne without a plan for housing and was unable or unwilling to provide stable housing for the Children.
Mother and Father appealed the CHINS designation, challenging the sufficiency of the evidence supporting the court’s findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supports CHINS designation	Mother and Father claimed stable housing and finances; CHINS unsupported.	DCS asserted Mother relocated without housing plan and failed to provide basic needs.	CHINS designation reversed; evidence insufficient.
Whether the CHINS order was a final, appealable judgment	Appeal filed before dispositional order became final.	Dispositional hearing produced a final judgment.	Appeal deemed timely; final judgment exists and review proceeds.
Whether the trial court correctly applied the standard of review for CHINS	Standard supports affirming CHINS if findings are supported by evidence.	Two-tier review governs CHINS: review of findings then judgment.	Court applied proper two-tier standard and reversed on sufficiency.

In re J.V., 875 N.E.2d 395 (Ind.Ct.App.2007) (final, appealable CHINS disposition exists after dispositional hearing)
In re N.E., 919 N.E.2d 102 (Ind.2010) (CHINS adjudication concerns the child’s condition, not parental culpability)
In re A.C., 905 N.E.2d 456 (Ind.Ct.App.2009) (two-tier standard for reviewing CHINS findings and judgment)
In re A.H., 913 N.E.2d 303 (Ind.Ct.App.2009) (affirms deference to trial court findings; focuses on evidence support)