S.E. v. Indiana Department of Child Services, 15 N.E.3d 37

Mother, who is deaf, appealed a termination of parental rights and challenged being required to testify via an interpreter; the trial court used a proceedings interpreter after not understanding Mother’s oral testimony.
S.E. was removed from Mother in 2011 and placed in foster care; multiple services were offered but Mother largely failed to participate or benefit.
Mother’s health and mental-health issues, including long-standing diagnoses and extensive prior hospitalizations, were central to the court’s concerns about parenting capacity.
Service providers repeatedly found Mother confrontational, noncompliant, or unwilling to engage in treatment, counseling, and mandated services; progress was described as minimal.
A guardian ad litem, case manager, and foster family all recommended termination of parental rights due to ongoing risks and S.E.’s thriving in foster care.
The trial court terminated Mother’s rights in a detailed order, concluding the conditions leading to removal would not be remedied and termination was in S.E.’s best interests; the appellate court affirmed the termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court violate due process by requiring sign-language testimony?	Mother argues interpreter-required testimony violated due process.	The State contends the interpreter ensured the court heard Mother’s testimony; waiver applies.	No due-process violation; procedure reasonable and within trial court discretion.
Is there sufficient evidence to support termination of parental rights?	Mother asserts progress and potential for reunification were not fully weighed.	Court correctly found reasonable probability that conditions would not be remedied and that best interests favor termination.	Yes; sufficient clear and convincing evidence supports termination and finding of best interests.

Castro v. State Office of Family & Children, 842 N.E.2d 367 (Ind. Ct. App. 2006) (due process balancing in parental-rights termination)
In re C.G., 954 N.E.2d 910 (Ind. 2011) (due process and procedures in CHINS terminations)
A.P. v. Porter Cnty. Office of Family & Children, 734 N.E.2d 1107 (Ind. Ct. App. 2000) (waiver of due-process claims in CHINS)
McBride v. Monroe Cnty. Office of Family & Children, 798 N.E.2d 185 (Ind. Ct. App. 2005) (waiver for first-on-appeal claims in termination)
In re K.S., 750 N.E.2d 882 (Ind. Ct. App. 2001) (waiver and procedures in permanency contexts)
In re E.M., 4 N.E.3d 636 (Ind. 2014) (two-step analysis for remedying removal conditions)
In re K.T.K., 989 N.E.2d 1225 (Ind. 2013) (parental rights; best interests; standard of review)
A.D.S. v. Ind. Dep’t of Child Servs., 987 N.E.2d 1150 (Ind. Ct. App. 2013) (best-interests framework and termination evidence)
In re S.P.H., 806 N.E.2d 874 (Ind. Ct. App. 2004) (child needs; waiting for parental readiness inappropriate)