In 2021, an Indiana mother and her teenage son lost contact after he moved away with his father; she later showed a court about 25 unanswered texts, and an October 26 ruling said she need not pay his college expenses
An Indiana mother who has had no contact with her teenage son for four years does not have to pay for his university education, an appeals court has ruled. The Court of Appeals of Indiana upheld a lower court decision that found the son had rejected his relationship with his mother. Under state law, this gave her a complete legal defence against being forced to pay for his education after high school. The ruling in case number 26A-DC-01758 (Jonathan M. Pratt v. Jamie L. Pratt) ends the father’s legal attempt to make his former wife contribute to their son’s higher education costs.
Family breakdown and relocation
According to court records from the Howard Circuit Court, Jonathan M. Pratt and Jamie L. Pratt ended their marriage in November 2020. They initially shared physical and legal custody of their son, who was born in January 2007. The family situation changed in July 2021, when Mr Pratt moved to Georgia with their son, who was then 14 years old. Mrs Pratt stayed in Indiana. After the move, the Howard Circuit Court changed the custody arrangement. Mr Pratt received sole legal and physical custody, while Mrs Pratt was allowed to spend time with her son by mutual agreement. However, after the move to Georgia in 2021, Mrs Pratt did not have any further parenting time with her son.
Unanswered messages presented as court evidence
When the son turned 18 in January 2025, Mr Pratt asked the court to order Mrs Pratt to help pay for their son’s education after high school as he prepared to graduate. During a hearing in July 2025 before Special Judge Douglas A. Tate, the court heard different accounts of why the mother and son had stopped communicating. Both Mrs Pratt and her son agreed that they had not spoken to or seen each other since 2021. The son testified that his mother had not contacted him during those four years. However, Mrs Pratt presented electronic evidence showing that she had tried to reach him. Photographs of text messages submitted as evidence showed that Mrs Pratt had sent around 25 messages to her son between 2021 and 2025. One of those messages was sent directly to him on his 18th birthday. Her son did not reply to any of the messages.
Trial court rules on relationship repudiation
In May 2026, the Howard Circuit Court issued its decision. It ruled that Mrs Pratt did not have to pay for college because her son had rejected his relationship with her. Mr Pratt appealed, arguing that the lower court had wrongly considered his son’s failure to respond while he was still a minor living under his father’s care and influence. Writing for the unanimous appeals panel, Judge Scheele rejected the father’s argument and upheld the lower court’s decision. Judges Brown and Kenworthy agreed with the ruling.
Legal standard for parental college contribution
Under Indiana law (Ind. Code § 31-16-6-2), parents are not automatically required to pay for their children’s education after high school. State courts can order parents to provide financial support for further education, but a child’s rejection of a relationship with a parent can serve as a complete legal defence against such an order. In the opinion, Judge Scheele referred to earlier court decisions, Lovold v. Ellis and Messner v. Messner. These cases define repudiation as a child’s complete refusal to take part in a relationship with a parent. The appeals court also addressed behaviour that begins before a child turns 18. The judges noted that although repudiation mainly concerns an adult child’s behaviour after turning 18, courts can consider actions that started during the teenage years if the behaviour continues without change into adulthood.The opinion referred to the trial judge’s original findings. Special Judge Tate stated: “While the court will tend to believe that a fourteen year old child ignoring his mother may be done at the influence of his father, not responding to your mother’s birthday wishes, or providing your mother with updated contact information when you turn eighteen, is an adult decision and a clear repudiation of that parent.” The appeals panel concluded that the trial court had acted within its authority by accepting Mrs Pratt’s documented text messages as more reliable evidence than her son’s testimony.“By college age, children of divorced parents must be expected to begin to come to terms with the reality of their family’s situation,” Judge Scheele noted, quoting an earlier appeals court decision, McKay v. McKay. “Whatever their biases and resentments, while one can understand how they got that way, when they become adults it is no longer appropriate to allow them to stay that way without consequence.”Mr Pratt was represented by attorney Dan J. May of Kokomo but failed to overturn the ruling. Mrs Pratt was represented by attorney Jeremy A. Peelle, also of Kokomo.
