Jennifer Lynn Goetz v. James Lawrence Franklin Goetz

── Jennifer Lynn Goetz v. James Lawrence Franklin Goetz ── Court: Indiana Court of Appeals Date: May 18, 2026 Author: Bailey Category: General FILED May 18 2026, 9:06 am CLERK Indiana Supreme Court Court of Appeals and Tax Court IN THE Court of Appeals of Indiana Jennifer Lynn Goetz, Appellant/Cross-Appellee-Respondent v. James L. Goetz, Appellee/Cross-Appellant-Petitioner May 18, 2026 Court of Appeals Case No. 25A-DC-2101 Appeal from the Hendricks Superior Court The Honorable Mark A. Smith, Judge Trial Court Cause No. 32D04-2105-DC-330 Opinion by Judge Vaidik Judges Bailey and Scheele concur. Court of Appeals of Indiana | Opinion 25A-DC-2101 | May 18, 2026 Page 1 of 24  Vaidik, Judge. Case Summary [1] Jennifer Lynn Goetz (“Mother”) and James L. Goetz (“Father”) had four children together before divorcing in 2022. In this high-conflict post-dissolution proceeding, Mother appeals the trial court’s denial of her motion to modify school placement, calculation of Father’s income for purposes of modifying his child-support obligation, denial of her request for attorney’s fees, and finding that she was in contempt. Father cross-appeals, arguing that the trial court erred in denying his request for sole legal custody as to educational decisions and instead ordering joint legal custody. [2] We affirm as to Mother’s claims. But because Mother and Father have made the children’s schooling a battleground, an award of joint legal custody as to educational decisions imposes an intolerable situation upon Mother and Father and is therefore not in the children’s best interests. Thus, we reverse the order of joint legal custody as to educational decisions only and remand for the trial court to award Father sole legal custody as to educational decisions. Facts and Procedural History [3] Mother and Father married in 2011 and have four children: S.G., born in April 2012; P.G., born in December 2013; L.G., born in June 2016; and G.G., born in December 2018. S.G., P.G., and L.G. have all been diagnosed with dyslexia and ADHD. During the marriage, Mother homeschooled the children once they reached school age. After Father filed for divorce in May 2021, Mother Court of Appeals of Indiana | Opinion 25A-DC-2101 | May 18, 2026 Page 2 of 24  and Father disagreed about whether S.G., P.G., and L.G. should attend public or private school for the 2021-2022 school year (G.G. was not yet school age). At the time, Mother worked as an aide in the Avon Community School Corporation, which is the district the family lived in, and she wanted to enroll the children there. Ultimately, S.G., P.G., and L.G. began attending public school in Avon that fall. All three children “started significantly below grade level.” Tr. Vol. 2 p. 164. [4] In April 2022, the trial court issued a decree of dissolution awarding Mother primary physical custody and the marital home in Avon. The court awarded Mother sole legal custody with the limitation that “[t]he children shall remain