In the Matter of R.L. (Minor Child) J.R. (Mother) v. Indiana Department of Child Services and Child Advocates, Inc.

Summary

The Indiana Supreme Court held that claim preclusion barred the Department of Child Services from filing a second CHINS petition because the second petition largely duplicated allegations that were or could have been litigated in the first proceeding. The court concluded that the new allegations did not overcome the preclusive effect of the first dismissal with prejudice, particularly given the agency's failure to inform Mother that the child could have been returned to her care. The court reversed the juvenile court and dismissed the second CHINS petition with prejudice.