Deitra Mangrum and Randy Mangrum v. Randi Mangrum and Bryce Walker

Summary

The Indiana Court of Appeals reviewed the termination of a grandparent visitation order involving Deitra and Randy Mangrum and Randi Mangrum and Bryce Walker. The court held that the grandparents waived their challenge to the change of judge but concluded that the trial court abused its discretion by terminating visitation under the Grandparent Visitation Act. The court reversed and remanded.

Holdings

1. The grandparents waived their challenge to the trial court's grant of the mother's motion for change of judge because they did not object when the motion was granted and raised the issue for the first time on appeal.
2. Indiana Code section 31-17-5-7 requires only that modification of a grandparent-visitation order serve the best interests of the child; it does not independently require proof of a substantial change in circumstances.
3. The trial court abused its discretion by terminating the grandparent-visitation order because the mother's petition relied substantially on reasons and evidence previously rejected or litigated, and termination rewarded the parents' continued noncompliance with the existing order.

Questions Presented

1. Whether the grandparents waived their challenge to the trial court's grant of the mother's motion for change of judge by failing to object below.
2. Whether the trial court abused its discretion by terminating the existing grandparent-visitation order.

Disposition

reversed_and_remanded