Jonathan M. Pratt, Appellant-Petitioner v. Jamie L. Pratt, Appellee-Respondent (2026)

MEMORANDUM DECISION

[1] We must dismiss this appeal for lack of jurisdiction under Indiana Appellate Rule 5, concluding that the appealed order is neither a final judgment nor an appealable interlocutory order. Jonathan M. Pratt (“Father”) is attempting to appeal the trial court's determination that his son repudiated the parent-child relationship with his mother, Jamie L. Pratt (“Mother”), and therefore, Mother was not obligated to contribute to the son's post-secondary education expenses.

[2] However, as Father notes, the trial court failed to rule on his Petition to Determine Arrears, which he filed the same day as his Petition for Post-Secondary Educational Expenses. See Appellant's App. Vol. 2 pp. 17 (CCS entries), 24–25 (Petition to Determine Arrears), 26–27 (Petition for Post-Secondary Educational Expenses). The trial court held a consolidated hearing on both petitions. See id. at 19 (containing a Hearing Journal Entry stating: “Cause submitted for hearing regarding Respondent's Motion for College Expenses and Motion to Determine Amount of Child Support Arrearage․ [T]he [c]ourt takes this matter under advisement.”); Tr. Vol. II pp. 3–4 (recognizing the hearing was for both issues). After taking the matters under advisement, the trial court only resolved the Petition for Post-Secondary Educational Expenses. See Appellant's App. Vol. 2 pp. 21–22 (Amended Order on Payment of College Expenses), 23 (Order on Payment of College Expenses).

[3] In pertinent part, Indiana Appellate Rule 5 confers appellate jurisdiction in appeals from (1) final judgments (as defined in Rule 2(H)) and (2) interlocutory orders as provided in Rule 14. In general, a judgment is a final judgment if “it disposes of all claims as to all parties” or satisfies other narrow exceptions (e.g., where the trial court directs the entry of a judgment under Trial Rule 54(B)). Ind. Appellate Rule 2(H). The appealed order is not a final judgment. The order fails to dispose of all claims, as it does not address Father's request to determine the child support arrearage, and it does not contain the “magic language” set forth in Trial Rule 54(B). See Georgos v. Jackson, 790 N.E.2d 448, 452 (Ind. 2003) (explaining that “the magic language of the rule ․ is intended to provide a bright line so there is no mistaking whether an interim order is or is not appealable”).

[4] As for interlocutory orders, the instant order does not support an interlocutory appeal as of right because it does not fit into one of the nine categories set forth in Appellate Rule 14(A). See App. R. 14(A).¹ And no steps were taken to perfect a discretionary interlocutory appeal. See App. R. 14(B). Under the circumstances, we lack appellate jurisdiction and are constrained to dismiss the appeal. See App. R. 5; Truelove v. Kinnick, 163 N.E.3d 344, 347 (Ind. Ct. App. 2021) (dismissing for lack of appellate jurisdiction). We, therefore, dismiss.²

[5] Dismissed.

FOOTNOTES

1.   The closest fit is an interlocutory order “[f]or the payment of money” under Appellate Rule 14(A)(1). But the trial court ruled that Mother was not obligated to contribute toward post-secondary education expenses. See, e.g., Whittington v. Magnante, 30 N.E.3d 767, 769 (Ind. Ct. App. 2015) (explaining that, to fit the category, the order must “directly order one of the parties to pay a sum to another party or to the court”); cf. Bayless v. Bayless, 580 N.E.2d 962, 964 (Ind. Ct. App. 1991) (applying a predecessor rule and explaining that the rule “does not authorize an appeal from an interlocutory order denying the payment of money”), trans. denied.

2.   In the Odyssey system, we reviewed the CCS to ascertain whether the trial court eventually addressed the arrearage issue. The CCS reflects that, after entry of the interlocutory order, Mother's ongoing child support obligation was terminated because of the son's age. However, the issue of arrearage was not addressed.

Foley, Judge.

Tavitas, C.J., and Weissmann, J., concur.