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S.H. v. D.H.

Citations: 796 N.E.2d 1243; 2003 Ind. App. LEXIS 1917Docket: No. 15A01-0309-CV-335

Court: Indiana Court of Appeals; October 10, 2003; Indiana; State Appellate Court

Narrative Opinion Summary

In this case, the appellant-mother challenged a trial court decision requiring both parents' consent for their minor daughter's abortion, contrary to Indiana Code section 16-34-2-4(a), which allows for one parent's consent. The mother, who had sole physical custody, faced opposition from the father, who sought a court order to prevent the abortion. The trial court's restraining order was overturned on appeal, as the appellate court determined that the statute's language clearly permits consent from only one parent. The appellate court criticized the trial court's interpretation requiring dual consent due to joint custody, emphasizing correct statutory interpretation aligned with constitutional protections for minors seeking abortions. Additionally, the appellate court addressed the issue of fetal viability, underscoring that such determinations are the purview of the attending physician, not the court, and found insufficient evidence for the trial court's viability ruling. The appellate court reversed the trial court's decision, highlighting the importance of accessible judicial review in ensuring justice and the professional conduct of counsel under pressing circumstances.

Legal Issues Addressed

Judicial Review and Access to Justice

Application: The opinion reinforced the principle that court determinations regarding abortion must be reviewable to ensure access to justice, and highlighted the uncertainty of medical determinations like fetal viability.

Reasoning: Court determinations regarding abortion must be reviewable to ensure access to justice, as mandated by Article 1, Section 12 of the Indiana Constitution.

Parental Consent for Minor's Abortion under Indiana Code Section 16-34-2-4(a)

Application: The appellate court determined that the trial court erred by requiring consent from both parents for the minor's abortion, as Indiana law mandates written consent from only one parent or legal guardian.

Reasoning: The court finds that the trial court erred, as Indiana Code section 16-34-2-4(a) stipulates that written consent from just one parent or legal guardian is sufficient for a minor to obtain an abortion.

Statutory Interpretation and Constitutional Protections

Application: The appellate court emphasized adherence to the clear language of the statute, rejecting the trial court's interpretation requiring both parents' consent, and affirmed that statutory interpretation should uphold constitutionality.

Reasoning: The appellate court emphasized that statutory construction should follow the clear language of the law, rejecting the trial court's interpretation that joint custody necessitates both parents' consent.

Viability Determination of Fetus

Application: The appellate court held that the attending physician, not the court, should determine fetal viability based on accepted medical standards, and found insufficient evidence for the trial court's viability determination.

Reasoning: The court clarified that the attending physician must assess the trimester of the pregnancy and the viability of the fetus according to accepted medical standards.