FILED
Sep 29 2026, 8:47 am
CLERK
Indiana Supreme Court
Court of Appeals
and Tax Court
IN THE
Court of Appeals of Indiana
In the Matter of the Paternity of O.S.C., Minor Child,
Brenden Carrell,
Appellant-Petitioner
v.
Katherine Schurman,
Appellee-Respondent
September 29, 2026
Court of Appeals Case No.
26A-JP-212
Appeal from the Hancock Circuit Court
The Honorable Cody B. Coombs, Magistrate
Trial Court Cause No.
30C01-2112-JP-419
Opinion by Judge Foley
Judges Vaidik and Altice concur.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 1 of 17
Foley, Judge.
[1] Brenden Carrell (“Father”) appeals the trial court’s order granting the request of
Katherine Shockley (“Mother”) 1 to relocate with the parties’ minor son
(“Child”) to Pennsylvania. The order also awarded Mother primary physical
custody and reduced Father’s parenting time. Father raises four issues for our
review, which we consolidate and restate as the following three issues:
I. Whether remand is required because the trial court did not
enter the findings and conclusions that Indiana Code
section 31-14-13-7.5 (“the Special Findings Statute”)
requires to support a modification of child custody;
II. Whether remand is also required because the trial court
placed the burden of proof for Mother’s relocation request
on Father, the nonrelocating parent; and
III. Whether the magistrate should be disqualified from
hearing the matter on remand.
[2] We remand. The trial court did not enter the findings and conclusions the
Special Findings Statute requires. It also misallocated the burden of proof on
relocation. On remand, the trial court must (1) enter an amended written order
containing the required custody findings and conclusions, and (2) reconsider the
relocation request under the correct statutory standard, entering more specific
1
Mother’s previous surname was Schurman, which appears in the record.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 2 of 17
findings and conclusions indicating that the trial court applied the correct
burden of proof on the issue. We deny Father’s request for disqualification.
Facts and Procedural History
[3] Father and Mother are the parents of Child, born in July 2021. Father filed this
paternity action in the Hancock Circuit Court in December 2021. The same
magistrate has presided over the hearings and issued the substantive orders in
the case. In January 2023, the trial court approved the parties’ Agreed Entry on
Parenting Time, Custody, and Child Support (“the Agreed Entry”). The parties
agreed “to equally share joint legal and physical custody” of Child. Appellant’s
App. Vol. 2 p. 18. They agreed to alternate parenting time weekly, beginning
on Mondays. Mother described the arrangement as a “week on, week off
basis,” with exchanges at Child’s daycare. Tr. Vol. II p. 15.
[4] In May 2024, Mother filed a petition to relocate. The trial court denied it,
directing Mother to “the statutory requirements for notices of intent to relocate”
and granting leave to correct and refile. Appellant’s App. Vol. 2 p. 23. In
August 2025, Mother filed the Verified Notice of Relocation and Motion to
Modify Custody and Parenting Time (“the Motion to Modify”). She sought to
relocate with Child to Pennsylvania and alleged a substantial change in
circumstances. Mother had remarried. Her husband (“Stepfather”) worked as
the training coordinator for a nuclear power plant in Pennsylvania. The couple
now had a child to whom Child was bonded. Mother said she had “no desire
to sever the relationship” between Child and Father. Id. at 29. She offered to
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 3 of 17
modify parenting time so that Father would have “the majority of all breaks
from school and the summer.” Id.
[5] Father filed a Verified Objection to Relocation of Mother and Child (“the
Objection”). He noted that the parties had shared a “week to week”
arrangement since the Agreed Entry, with Mother in Hancock County and
Father in Madison County. Id. at 24. He stated that Mother had recently
“stopped bringing the child to daycare” and had “requested copies of [Child’s]
records from the daycare.” Id. Father asserted that he was a dedicated parent.
He did not want Mother “to cut him off from his child by her unilateral choice
to relocate.” Id. at 25.
[6] A hearing set for September 2025 was continued, on Father’s motion, to
December 2025. In the meantime, Mother relocated to Pennsylvania in
October 2025. Mother would later testify that she took Child with her during
her parenting weeks and returned him to Indiana for Father’s parenting time.
She explained, “I relocated. I did not relocate my son. I was taking him to
Pennsylvania to visit and then bringing him back to Indiana so . . . Father can
exercise his parenting time . . . .” Tr. Vol. II p. 9. Father notified the court and
objected to the change to Child’s living arrangements. The trial court issued an
order on November 14, 2025, requiring Mother to return Child to Indiana and
enjoined her from removing Child from the State. The court later denied
Mother’s Trial Rule 60(B) motion to set aside that order.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 4 of 17 [7] The trial court heard the Motion to Modify and the Objection on December 11,
2025. At the outset, the trial court addressed the order of proof and the burden
of proof. Father’s counsel stated that “Mother has an affirmative obligation to
prove the justification for the relocation.” Id. at 5. Counsel added that the
Objection “would go first” in the presentation of evidence, but that Mother
“would still be the moving party.” Id. The trial court disagreed, stating:
The law talks about, um, whether the Court needs to restrain the
child from leaving the State, um, which is language that falls on
Father, not on Mother, because that wouldn’t be restraining
Mother from, um, removing the child from the State. That
would be re-- I mean, Mother wouldn’t be arguing for that.
Father would be arguing for that. That’s why I think the burden
actually falls on Father.
Id.
[8] Mother testified that she met Stepfather in 2023 while visiting her sister in
Pennsylvania. Stepfather moved to Indiana in 2024, shortly before the couple’s
child was born. His job required frequent travel throughout the country. He
was later recruited for a position at a nuclear power plant in Pennsylvania,
where he had previously applied. Mother and Stepfather married in April 2025.
About a month later, Stepfather returned to Pennsylvania to take the position.
It involved a substantial pay increase and a traditional work schedule. Mother
remained in Indiana until October 2025, when she began traveling back and
forth with Child. The plan was for Mother to stay at home to care for Child
and his younger half-sibling.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 5 of 17 [9] Father testified about his weekday work schedule, which was compatible with
Child’s daycare hours. He also presented evidence about Mother’s handling of
parenting time and the sharing of information. Text messages indicated that
when Mother held Child’s first birthday party, she invited Father but said his
family could not come. She said they could celebrate during his parenting time,
but Father said his family was not available. Mother acknowledged that she
had not provided the Court with her Pennsylvania address until testifying at the
hearing and that she only disclosed the address to Father “after the fact,” in
“the first week of November.” Id. at 9. She had also stopped taking Child to
the Indiana daycare.
[10] The trial court ruled from the bench and granted Mother’s request to relocate
and modify custody. It later reduced the decision to a written order. In its oral
ruling, the court noted that the parties had “week on, week off” parenting time,
were “taking equal time” with Child, and were both “good parents.” Id. at 98.
It also explained that “there is not a way to do an equal parenting time split
based on the distance between the parties.” Id. at 99. Looking at “all the
factors . . . that the Court is supposed to review in the relocation statute and
motions to modify, et cetera,” the court called it “a close and difficult call.” Id.
The court then announced, “I am going to modify custody. Mother will be
primary physical custodian of the child. The parties will share joint legal
custody of the child.” Id. Turning to parenting time, the court set exchanges in
Dayton, Ohio. It described this as “an unequal travel arrangement because
Mother is the one that left Indiana.” Id. at 100. It gave Father video contact
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 6 of 17
with Child “at least every other day.” Id. at 102. Addressing the birthday text
messages, the court remarked that Mother’s approach to the special event “does
not fit within the spirit of the parenting time guidelines,” and told her to make
better efforts. Id. at 101.
[11] After the court announced its decision, Father’s counsel asked the court to enter
findings and conclusions. The court responded that “there wasn’t a request for
Findings of Fact before I made my decision, and the Court didn’t sua sponte . .
. request Findings of Fact.” Id. at 103. The court invited counsel to submit a
proposed order consistent with its oral decision, but concluded that “[t]he
request for Findings of Fact . . . has been waived.” Id. at 105. It also asked
Mother’s counsel to prepare a proposed order. Within a week, Father filed a
Verified Written Request for Findings of Fact and Conclusions of Law under
Trial Rule 52(A). The court denied the request “as [it] was not made until after
the Court issued its verbal decision.” Appellant’s App. Vol. 2 p. 14.
[12] The trial court entered its written order (“the Order”) on December 29, 2025.
The parties would continue to have joint legal custody. The court modified
physical custody to give Mother primary physical custody, finding that “[s]aid
modification is in the child’s best interest.” Id. at 17. The court found that
“[s]ince the last entry of this Court, Mother has remarried and has had another
child,” that “Mother’s husband has relocated to Pennsylvania for employment
which has enabled [M]other to stay at home with the children,” and that, “[a]s
such, Mother’s request to relocate is granted.” Id. at 16. Father would have
“one weekend a month,” along with “66% of winter break, all of fall and spring
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 7 of 17
break, and most of the summer unless otherwise agreed upon by the parties.”
Id. at 17. The Order provided for video calls “no less than every other day,”
and set parenting-time exchanges in Dayton, Ohio. Id. Father now appeals.
Discussion and Decision
I. Special Findings Statute
[13] Father argues that the Special Findings Statute required the trial court to enter
findings of fact and conclusions of law supporting the modification of physical
custody. He contends the court erred in two ways. It did not enter the required
findings and conclusions. And it wrongly concluded that he waived the issue.
[14] We review the scope and meaning of a statute de novo. Garner v. Kempf, 93
N.E.3d 1091, 1094 (Ind. 2018). If a statute is clear and unambiguous, we apply
its words and phrases “in their plain, ordinary, and usual sense.” Id. (quoting
KS&E Sports v. Runnels, 72 N.E.3d 892, 898–99 (Ind. 2017)).
[15] The Special Findings Statute directs that a trial court “shall include the court’s
findings of fact and conclusions of law on which the custody order is based.”
Ind. Code §§ 31-14-13-7.5(b)(1) (paternity cases), 31-17-2-8.2(b)(1) (dissolution
cases). A “custody order” includes a final order modifying custody. I.C. §§ 31-14-13-7.5(a), 31-17-2-8.2(a). The statute means what it says. It requires a trial
court to include the court’s findings and conclusions in support of a custody
order. Holstein v. Holstein, 283 N.E.3d 233, 237 (Ind. Ct. App. 2026)
(referencing the same statutory language in a different context).
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 8 of 17 [16] Next, the findings and conclusions must be set forth in the trial court’s written
order. See Ind. Trial Rule 58(A) (providing that, “upon a decision of the court,
the court shall promptly prepare and sign the judgment”); T.R. 54(A) (defining
“judgment” to “include[] a decree and any order from which an appeal lies”);
I.C. §§ 31-14-13-7.5(b)(1), 31-17-2-8.2(b)(1) (directing that the findings and
conclusions “shall be included in a custody order” (emphasis added)). The
findings must identify the basis for the custody decision. I.C. §§ 31-14-13-7.5(b)(1), 31-17-2-8.2(b)(1); see also Dowdell v. State, 720 N.E.2d 1146, 1152 (Ind.
1999) (“The principal purpose of findings of fact ‘is to have the record show the
basis of the trial court’s decision so that on review the appellate court may more
readily understand the former’s view of the controversy.’” (quoting Love v. State,
272 N.E.2d 456, 458 (Ind. 1971))).
[17] Mother acknowledges that Father “raises a legitimate concern regarding the
absence of detail[ed] findings” under the Special Findings Statute. Appellee’s
Br. p. 8. But she claims the “issue does not warrant reversal” because Father
waived the argument. Id. She argues he waived the argument by not requesting
findings under Trial Rule 52(A), which ordinarily requires a written request
before evidence is admitted. But that rule also provides that the court “shall
make special findings of fact without request . . . in any . . . case provided by
these rules or by statute.” T.R. 52(A) (emphasis added). The Special Findings
Statute is such a statute. The obligation to enter findings and conclusions
therefore applies without a request, and Father did not waive the argument.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 9 of 17 [18] The Order fails to satisfy the requirement of the Special Findings Statute. The
Order states that “[s]ince the last entry of this Court, Mother has remarried and
has had another child,” that “Mother’s husband has relocated to Pennsylvania
for employment which has enabled [M]other to stay at home with the
children,” and that, “[a]s such, Mother’s request to relocate is granted.”
Appellant’s App. Vol. 2 p. 16. Indiana Code section 31-14-13-6 governs the
modification of child custody and provides that “[t]he court may not modify a
child custody order unless: (1) modification is in the best interests of the child;
and (2) there is a substantial change in one (1) or more of the factors that the
court may consider under section 2 and, if applicable, section 2.5 of th[at]
chapter.” The court modified custody, but its only reference to these statutory
requirements came later in the Order, where the trial court stated that “Said
modification is in the child’s best interest.” Appellant’s App. Vol. 2 p. 17. The
trial court’s conclusory statement fails to identify the facts and statutory factors
the trial court relied upon to make its best-interests determination. Further, the
Order provides us no basis to review the modification. We must remand for
findings and conclusions supporting the custody decision. Holstein, 283 N.E.3d
at 237 (recognizing that remand for adequate findings, not reversal, is the
remedy for insufficient findings); cf. In re G.V., 274 N.E.3d 996, 1002 (Ind. Ct.
App. 2026) (remanding, in the CHINS context, for entry of proper findings).
[19] Father asks for more than a remand. He asks us to reverse the Order, remand
for a new evidentiary hearing, “reassign” the case to a different judge, and
restore equal parenting time in the interim. See Appellant’s Br. pp. 35–36. We
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 10 of 17
decline. Where inadequate findings in a trial court’s order leave us unable to
determine the theory on which a case was decided, the remedy is to remand the
case for the entry of adequate findings, not to reverse. Holstein, 283 N.E.3d at
237. We therefore remand for the trial court to enter the findings of fact and
conclusions of law on which its custody modification is based, as the Special
Findings Statute requires. In Part III, we separately address the request for a
different judge, which we regard as a request to disqualify the magistrate.
II. Burden of Proof
[20] Father next argues that the trial court misapplied the relocation statute. He
contends the court placed the burden of proof on him rather than on Mother, as
the relocating parent. The allocation of a statutory burden of proof is a
question of law that we review de novo. See Garner, 93 N.E.3d at 1094. In
conducting appellate review, we begin with a presumption that the trial court
followed the law and applied the correct burden of proof. Moran v. State, 622
N.E.2d 157, 159 (Ind. 1993). That presumption is not conclusive. See id. It is
overcome when the trial court’s own remarks disclose use of an erroneous
standard “with clarity and certainty.” Id. It is also overcome when the trial
court’s findings collectively present an unjustifiable risk that the court did not
follow the law. Ramsey v. Ramsey, 863 N.E.2d 1232, 1239 (Ind. Ct. App. 2007).
[21] In Justice v. State, the trial court announced that the criminal defendant had not
“met the burden” for self-defense. 237 N.E.3d 1154, 1159 (Ind. Ct. App. 2024),
trans. denied. The remark indicated that the trial court incorrectly placed the
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 11 of 17
burden on the defendant, when the law placed it on the State, so this court held
the presumption be overcome. Id. A neutral description of the court’s task is
different. In Browell v. Bagby, a relocation case, the court’s statement that it
must now determine whether the move is in the best interest of the children did
not overcome the presumption that the court correctly applied the law, because
it said nothing about who bore the burden. 875 N.E.2d 410, 415 (Ind. Ct. App.
2007). In contrast, in Ramsey, the trial court entered findings regarding
grandparent visitation but did not refer to the presumption that a fit parent acts
in a child’s best interests. 863 N.E.2d at 1239. When read as a whole, the
order gave “cause to worry” that the court had not applied the presumption,
creating an unjustifiable risk that it did not follow the law. Id.
[22] Indiana Code chapter 31-17-2.2 governs relocations. See I.C. § 31-14-13-10.5.
Section 1 generally requires a relocating parent to file a notice of intent to
relocate. Within twenty days, the nonrelocating parent must respond. I.C. §
31-17-2.2-5(a). Section 5 (“the Relocation Statute”) governs responses. If a
nonrelocating parent objects to the relocation of the child, the response must
include “[a] motion requesting: (i) a temporary or permanent order to prevent
the relocation of the child; and (ii) the modification of a custody, parenting
time, grandparent visitation, or child support order as a result of the
relocation.” I.C. § 31-17-2.2-5(a)(3)(B). It must also include a request for a
hearing “on the motion” filed. I.C. § 31-17-2.2-5(a)(3)(C). When a party has
requested a hearing, “the court shall hold a full evidentiary hearing to allow or
restrain the relocation of the child and to review and modify, if appropriate, a
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 12 of 17
custody order, parenting time order, grandparent visitation order, or child
support order.” I.C. § 31-17-2.2-5(d).
[23] The Relocation Statute allocates the burden of proof in two steps. Subsection
(e) sets forth the initial burden: “The relocating individual has the burden of
proof that the proposed relocation is made in good faith and for a legitimate
reason.” I.C. § 31-17-2.2-5(e). “If the relocating individual meets the burden of
proof under subsection (e), the burden shifts to the nonrelocating parent to
show that the proposed relocation is not in the best interest of the child.” I.C. §
31-17-2.2-5(f). The relocating parent thus bears the initial burden. This court
has applied the burden-shifting framework in that order. See Pilkington v.
Pilkington, 227 N.E.3d 885, 894 (Ind. Ct. App. 2024); see also id. at 896 n.9
(addressing burden shifting).
[24] The trial court’s comments indicate a departure from the burden-shifting
framework required by the Relocation Statute. Before hearing evidence, the
trial court addressed the order of proof and the burden of proof. Father’s
counsel stated that “Mother has an affirmative obligation to prove the
justification for the relocation.” Tr. Vol. II p. 5. He added that Father, as the
nonrelocating parent, “would go first” in the presentation of evidence, but that
Mother “would still be the moving party.” Id. The trial court disagreed with
counsel, stating:
The law talks about, um, whether the Court needs to restrain the
child from leaving the State, um, which is language that falls on
Father, not on Mother, because that wouldn’t be restraining
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 13 of 17
Mother from, um, removing the child from the State. That
would be re-- I mean, Mother wouldn’t be arguing for that.
Father would be arguing for that. That’s why I think the burden
actually falls on Father.
Tr. Vol. II p. 5.
[25] Mother reads the record differently, attributing counsel’s statement to the trial
court. She asserts: “The record reflects that the trial court and both parties’
counsel acknowledged this burden-shifting framework. The court stated,
‘Mother has an affirmative obligation to prove the justification for the
relocation . . . I believe they would still be the moving party.’” Appellee’s Br.
pp. 13–14 (quoting Tr. Vol. II p. 23). But that was Father’s counsel’s statement,
not the court’s ruling. The court’s response was to place the burden on Father.
The court appears to have conflated the order of proof with the burden of proof.
The statute assigns to Mother the initial burden to prove a good faith and a
legitimate reason for the relocation. The trial court instead placed the initial
burden on Father. That was error.
[26] Mother argues in the alternative that any error was harmless. She asserts that
the court “heard evidence from both sides” and that “[t]here is no indication
that the trial court misapplied or misunderstood the burden of proof.” Id. at 14.
She points to the trial court’s oral remarks, noting that “[t]he court explicitly
stated it was ‘looking at all the factors, uh, that the Court is supposed to review
in the [R]elocation [S]tatute and motions to modify, et cetera, it is a close and
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 14 of 17
difficult call.’” Id. at 15 (quoting Tr. Vol. II p. 99). Mother argues that these
remarks “demonstrate[] compliance with statutory requirements.” Id.
[27] We disagree. The court’s own statement, quoted above, gives us “cause to
worry” that it misapplied the applicable burden. Ramsey, 863 N.E.2d at 1239.
Nothing in the written order identifies the correct standard or indicates that the
court applied it, creating an unjustifiable risk that the trial court did not follow
the law. As in Part I, Father asks for a new hearing before a different judge.
Again, we decline. This kind of error is curable. It is not a basis for reversing
the relocation decision. Id. at 1240 (remanding for the entry of “more specific
findings and conclusions” to indicate that the trial court applied the correct
legal standard). We therefore remand for the trial court to apply the burden of
proof as the statute allocates it and to enter more specific findings and
conclusions confirming that it applied the correct legal standard. 2
III. Disqualification
[28] Father asks that we “reassign” the matter to a different judge on remand. This
Court has authority to grant appropriate relief on appeal. See Ind. Appellate
Rule 66(C)(10) (authorizing this Court to “grant any other appropriate relief”).
2
Because the missing findings and the burden-of-proof error each independently require remand, we do not
reach Father’s remaining challenge to the trial court’s consideration of the statutory relocation factors,
including whether Mother thwarted Father’s contact with Child. See Indiana Code section 31-17-2.2-1(c)(4).
The trial court should address the statutory factors when it reconsiders the relocation request on remand.
Father also raises a constitutional challenge to the burden-shifting framework where, as here, the parties
shared physical custody. He did not present that argument to the trial court. A party generally may not raise
the constitutionality of a statute for the first time on appeal. Monschein v. LaLonde, 701 N.E.2d 1275, 1277
(Ind. Ct. App. 1998). The constitutional argument is therefore waived. See id.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 15 of 17
Father’s request, however, is contained in a single sentence, offered without
cogent argument or citation to authority, and it is therefore waived. See Ind.
Appellate Rule 46(A)(8)(a) (requiring citation to supporting authority and
cogent reasoning); Topp v. Leffers, 838 N.E.2d 1027, 1029 n.1 (Ind. Ct. App.
2005) (identifying appellate waiver for noncompliance with our appellate rules),
trans. denied. Waiver aside, the request for reassignment, which we interpret as
a request for disqualification, fails on the merits.
[29] Trial Rule 76(C)(4) governs requests for disqualification and requires a verified
petition setting forth the grounds. Moreover, this court does not allocate cases
among trial court judges and magistrates. Rather, Trial Rule 79 governs the
appointment of a special judge, with “the provisions of th[e] rule constitut[ing]
the exclusive manner for the selection of special judges in circuit, superior, and
probate courts in all civil and juvenile proceedings.” Ind. Trial Rule 79(A).
[30] In requesting disqualification, Father did not comply with Trial Rule 76(C)(4).
Furthermore, “[t]he law presumes that a judge is unbiased and unprejudiced.”
L.G. v. S.L., 88 N.E.3d 1069, 1073 (Ind. 2018). “To overcome that
presumption, the party seeking disqualification must identify facts reflecting the
judge’s actual bias or prejudice.” State ex rel. Allen v. Carroll Cir. Ct., 226 N.E.3d
206, 217 (Ind. 2024). This presumption is not overcome by the mere existence
of adverse or even erroneous rulings. Id.; Newville v. State, 566 N.E.2d 567, 572
(Ind. Ct. App. 1991), trans. denied.
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 16 of 17 [31] Even looking past the procedural impediments, the two errors we have
identified are legal ones, and neither the record nor the challenged order
discloses any basis to conclude that the magistrate cannot fairly consider the
matter on remand. We therefore deny Father’s request for disqualification.
Conclusion
[32] The trial court failed to enter findings of fact and conclusions of law supporting
its custody decision as required by the Special Findings Statute. The court also
misallocated the burden of proof required by the Relocation Statute. We
therefore remand for the trial court to (1) enter an amended written order
containing the required child custody findings and (2) revisit its relocation
decision, confirming use of the correct legal standard on the issue through the
entry of more specific findings and conclusions. We deny Father’s request for
disqualification of the magistrate.
[33] Remanded.
Vaidik, J., and Altice, J., concur.
ATTORNEY FOR APPELLANT
Nathan K. Vining
Vining Legal
Indianapolis, Indiana
ATTORNEY FOR APPELLEE
Dorothy Ferguson
Law Office of Dorothy Ferguson
Anderson, Indiana
Court of Appeals of Indiana Opinion 26A-JP-212 September 29, 2026 Page 17 of 17