Opinions March 1, 2021

Indiana Court of Appeals 

In Re the Termination of the Parent-Child Relationship of: A.L. (Minor Child) and A.N. (Mother) v. Indiana Department of Child Services (mem. dec.); In Re the Termination of the Parent-Child Relationship of: G.L. (Minor Child) and A.N. (Mother) v. Indiana Department of Child Services; In Re the Termination of the Parent-Child Relationship of: R.L. (Minor Child) and A.N. (Mother) v. Indiana Department of Child Services
20A-JT-1631; 20A-JT-1633; 20A-JT-1639

Juvenile termination of parental rights. Affirms the termination of mother A.N.’s parental rights to her three children, A.L., G.L. and R.L. Finds A.N. has waived her challenge to the admission of Petitioner’s Exhibit 1 by failing to provide a cogent argument, and even if there were a discovery violation, the Jay Circuit Court did not abuse its discretion. Also finds A.N. has waived her argument that the Indiana Department of Child Services violated her due process rights because she failed to object on due process grounds in the trial court and she failed to specific any constitutional basis for her due process claim; waiver notwithstanding, her due process argument fails on the merits because she did not establish a risk of error arising from DCS’ actions. Finally, finds there is sufficient evidence to support the trial court’s termination judgment.