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Indiana Court of Appeals
Reid J. Cowan v. State of Indiana
No. 25A-CR-1744

Criminal. Interlocutory appeal from the Grant Superior Court, Judge Nathan D. Meeks. Affirms the denial of Cowan’s motion challenging venue on a Level 4 felony child solicitation charge. Holds that Grant County is a proper venue under Indiana Code section 35-32-2-1(d) because Cowan’s alleged travel to Grant County to meet a person he believed to be a child constituted an act committed in furtherance of the charged offense. Rejects Cowan’s argument that the offense was complete at the time of the online communications and that travel was merely a sentencing enhancement, distinguishing prior case law decided before the legislature amended the statute to make travel an element of Level 4 felony child solicitation. Concludes that because travel is an element of the charged Level 4 offense, venue in Grant County is proper. Appellant’s attorneys: Michael C. Cunningham; Kelly N. Pyle. Appellee’s attorney: Office of the Indiana Attorney General.

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Indiana Court of Appeals
James Irwin Richter v. Neha Bhatnagar Richter
No. 25A-DC-1593

Civil. Appeal from the Hamilton Superior Court, Special Judge Stephenie K. Gookins. Affirms the trial court’s order awarding Mother sole legal custody of the parties’ child, modifying Father’s child support obligation and authorizing the issuance of a passport for the child. Holds the trial court did not abuse its discretion in modifying legal custody from joint to sole where the record showed ongoing conflict, unilateral decision-making by Father and an inability to effectively co-parent, constituting a substantial and continuing change in circumstances rendering joint legal custody no longer in the child’s best interests. Further holds the trial court did not err in calculating Father’s weekly gross income for child support purposes based on his tax returns reflecting total annual income. Concludes the trial court did not abuse its discretion in ordering that the child obtain a passport in light of his advancement to high school and opportunities for international immersion trips, finding a substantial change in circumstances and implementing safeguards through the parenting coordinator to address Father’s concerns. Appellant’s attorneys: Bryan L. Ciyou; Anne M. Lowe. Appellee’s attorney: Dyllan M. Kemp.

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Indiana Court of Appeals
In the Matter of: A.B. and B.B. (Minor Children), E.B. (Mother) v. Indiana Department of Child Services
No. 25A-JC-1315

Civil. Appeal from the Brown Circuit Court, Judge Mary Wertz. Affirms the adjudication of A.B. and B.B. as children in need of services. Holds that even if the trial court erred in denying Mother’s emergency motion to continue the fact-finding hearing based on one of her attorneys’ hospitalizations, Mother failed to establish prejudice warranting reversal, particularly where she was represented by two attorneys and did not show how the denial affected her ability to secure expert testimony or prepare her defense. Further holds the trial court did not abuse its discretion in excluding the results of Stepfather’s unstipulated polygraph examination, reiterating that polygraph evidence is generally inadmissible absent a valid stipulation and rejecting Mother’s argument for a civil-case exception. Concludes that Mother did not demonstrate reversible error in either the denial of the continuance or the exclusion of the polygraph evidence. Appellant’s attorneys: Bryan L. Ciyou; Anne M. Lowe. Appellee’s attorney: Office of the Indiana Attorney General.

This content was created with the assistance of artificial intelligence and has been reviewed by an editor for accuracy.