S.C. v. Indiana Department of Child Services, Local Knox County Office (mem. dec.), 42A01-1611-JT-2618

Child born Feb. 13, 2013; parents S.C. (Father) and T.R. (Mother) had history of methamphetamine use and instability; Child removed Aug. 2014 after being left with a friend and found ill.
DCS filed CHINS petition Aug. 14, 2014; parents later admitted CHINS; Child placed with maternal aunt (Aunt S.C.), who provided long-term care and sought adoption.
Dispositional case plan required weekly contact with DCS, stable housing and income, sobriety, drug screens, and visitation; Father briefly obtained employment and visited but refused inpatient treatment and repeatedly avoided drug screens.
Father ceased contact in Jan. 2015 to evade arrest, later incarcerated on multiple matters and had minimal contact with DCS or Child for ~18 months; Mother voluntarily relinquished parental rights in July 2016.
DCS filed termination petition Mar. 15, 2016; trial court terminated Father’s parental rights Oct. 18, 2016, finding reasonable probability conditions would not be remedied and termination served Child’s best interests.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (DCS)	Held
Whether the trial court clearly erred by terminating Father's parental rights	Father argued he partially complied with recommendations, planned to obtain housing and employment post-release, and DCS failed to provide reunification services during his incarceration	DCS argued Father had long history of substance abuse, criminality, refusal of treatment, loss of contact and support, and that continuation threatened Child; DCS had provided services pre-incarceration	Court affirmed: Father conceded removal/plan elements; trial court not clearly erroneous in finding reasonable probability conditions would not be remedied or that termination was in Child's best interests; DCS had provided reasonable reunification efforts pre-incarceration

In re G.Y., 904 N.E.2d 1257 (Ind. 2009) (standard of review and parental-rights termination principles)
Troxel v. Granville, 530 U.S. 57 (2000) (parental liberty interest precedent)
K.E. v. Ind. Dep’t of Child Servs., 39 N.E.3d 641 (Ind. 2015) (termination as last resort)
In re I.A., 934 N.E.2d 1127 (Ind. 2010) (parental-rights termination analysis)
In re A.K., 924 N.E.2d 212 (Ind. Ct. App. 2010) (disjunctive interpretation of remediation/threat prongs)
Bester v. Lake Cnty. Office of Family & Children, 839 N.E.2d 143 (Ind. 2005) (trial court findings and judgment review standard)
A.D.S. v. Ind. Dep’t of Child Servs., 987 N.E.2d 1150 (Ind. Ct. App. 2013) (totality-of-evidence and permanency considerations in best-interests analysis)
In re C.C., 788 N.E.2d 847 (Ind. Ct. App. 2003) (purpose of termination is child protection)
In re H.L., 915 N.E.2d 145 (Ind. Ct. App. 2009) (reasonable-efforts requirement does not itself nullify termination where parent fails to participate)