R.L. v. Indiana Department of Child Services & Child Advocates, Inc.Annotate this Case
The Supreme Court reversed the judgment of the juvenile court finding that R.L. was a child in need of services (CHINS), holding that the Department of Child Services (DCS) should have been barred from filing a successive CHINS action after the initial CHINS petition was dismissed with prejudice.
In 2017, DCS filed a petition alleging that R.S. was a CHINS. The juvenile court determined R.L. was not a CHINS and dismissed the action with prejudice. In 2018, DCS filed a subsequent petition alleging R.L. was a CHINS. Mother moved to dismiss the petition on claim preclusion grounds. The juvenile court denied the motion and found R.L. was a CHINS. The Supreme Court reversed, holding that Mother's motion to dismiss should have been granted because, under the framework of Matter of Eq.W., 124 N.E.3d 1201 (Ind. 2019), the subsequent petition filed by DCS should have been barred by the doctrine of claim preclusion.