TL;DR
An Indiana mother presented about 25 unanswered texts in a dispute over who should pay her adult son’s college expenses. The court ruled she didn’t have to contribute.
Indiana has recognized this kind of defense since 1994. The new decision applies existing law and isn’t binding precedent.
I’ve kept contact records myself. This case shows why the dates, the actual messages and the way evidence is challenged can matter years later.
The mother said she’d sent the texts. Her son said he hadn’t heard from her.
By the time an Indiana judge heard the dispute, they hadn’t seen or spoken to each other for about four years. The mother had photographs of roughly 25 texts she said she’d sent between 2021 and 2025, including one on her son’s eighteenth birthday. She said she’d received no reply.
They were in court because the son’s father wanted the mother ordered to help pay for college.
The trial court said no. On October 26, 2026, the Indiana Court of Appeals upheld that decision.
For me, the part worth writing about is the record she kept. Those messages were still there when the case reached a judge.
What happened in the Pratt case
Jonathan and Jamie Pratt divorced in 2020. They originally shared custody. In July 2021, their son, then fourteen, moved to Georgia with his father. His mother stayed in Indiana. The father received sole custody, and the mother was granted parenting time under an arrangement the parents were to agree on.
The mother didn’t exercise parenting time after the move. According to the decision, she and her son hadn’t spoken or seen each other since 2021.
Their son turned eighteen on January 18, 2025. The following month, his father petitioned the court to make the mother contribute to college expenses.
At the hearing, the son testified that he hadn’t received any contact from his mother since 2021. She gave a different account. She said she’d continued sending texts, received no replies and had photographs of the messages. The court admitted those photographs.
In May 2026, the trial judge found that the son had repudiated his relationship with his mother. That’s the legal term Indiana uses when an adult child completely refuses to participate in a relationship with a parent. Indiana courts have held that a parent in that situation may not have to make a court-ordered contribution to college expenses.
The father appealed. The appellate judges upheld the result.
This appeal was about college expenses. The court didn’t decide whether any ordinary child-support obligation should change.
The law is older than this case
I wanted to understand whether the judges had created something new. They hadn’t.
Indiana law lets a judge order parents to contribute to a child’s education after high school, depending on factors that include the child’s ability and the family’s finances. But there’s no automatic requirement that every divorced parent pay for college.
Back in 1994, the Indiana Court of Appeals decided McKay v. McKay. A twenty-year-old son refused a relationship with his father even after attempts to reconnect. The court concluded that an adult child who completely rejects a parent may not be able to use the court to force that parent to fund college.
Later decisions applied and explained that rule. Lovold v. Ellis (2013) confirmed the repudiation defense. Messner v. Messner (2019) explained that judges may look at a child’s behavior before eighteen when that same refusal continues into adulthood.
That birthday matters. A fourteen-year-old caught in a difficult divorce isn’t held to the same legal standard as an adult. In Pratt, the trial judge even acknowledged that a young child’s silence could reflect influence from a parent. The judge didn’t make a finding that the father had caused the estrangement. The legal decision focused on the son’s conduct after he became an adult.
There’s another important limit. Pratt is a memorandum decision. Other Indiana courts may consider its reasoning, but they don’t have to follow it. The published cases established the rule; this decision applies it to this family’s facts.
The messages the court could actually see
The father argued that the son hadn’t received contact from his mother. He also argued that she hadn’t tried other ways of reaching him, such as cards or presents.
The mother said she’d texted. The photographs gave the judge something to examine rather than relying only on two conflicting accounts of what happened over four years.
The father challenged the photographs as unauthenticated in a brief filed after the hearing, then raised the issue again on appeal. He argued that the mother hadn’t provided enough proof that the photographs were what she said they were. But when the photographs were offered at the hearing, he’d objected only to relevance: whether they related to the issue being decided.
The appeals court said the authenticity objection came too late. The legal word is waiver. An objection generally has to be made when the evidence is offered, and the reason given then matters. Raising a different reason later won’t ordinarily fix it.
So I wouldn’t describe this as a court proving that every text was delivered, read or understood. The court admitted the photographs, believed the mother’s account and found enough evidence to support its decision. The appeals court wasn’t going to hear the witnesses again or decide which one seemed more credible.
It also matters that the mother’s outreach wasn’t confined to the last few weeks before the hearing. The photographs covered several years. One message was sent on his eighteenth birthday.
Compare that with Koontz v. Scott (2016). There, a father argued that his son had rejected him. The court found that the father himself had gone nearly six years without contacting the boy. He began leaving brief messages around the time the mother sought college expenses. The son testified that he wanted a relationship with his father but was unsure how to restart it. The court declined to find repudiation and upheld the father’s obligation to contribute.
In Koontz, the father didn’t have years of attempted contact behind him, and his son told the judge he was open to a relationship. That’s a very different record from the one in Pratt.
Why I kept mine
I’ve written about my own records before. In The Math of Silence, I went back through phone logs from February and March 2011. I counted thirty-six outgoing calls to my sons and one incoming call.
That was a painful number to write down, but it was also a number I could check. I had call records rather than fifteen years of memory competing with someone else’s memory.
In The Phone Was Never the Problem, I wrote about giving my sons phones so they could reach me. I tried to make contact easier for them. The records and the conversations I documented over time are part of how I remember those years now.
The value of a dated record feels familiar to me. I also think about the years when the son was still a child. I wouldn’t want someone reading one of my call logs and deciding they knew everything my boys were dealing with at the other end.
I can show that I called. I’ve saved emails, dates and other records of what I tried. Some records preserve another person’s exact words. Others preserve what I wrote down at the time, including my assumptions. Those aren’t all the same kind of evidence, and I don’t want to treat them as though they are.
The mother in Pratt had years of messages to show the judge. That mattered in the college-expense ruling. I don’t know enough about their family to say why they stopped talking, and I’m not going to borrow their story to explain mine.
For me, this is a reason to keep the original records, not a reason to send more messages to someone who has asked for space. None of that requires turning a relationship into a legal case. I wish these were things families never had to think about.
I still have my old records too.
Author’s Note
This article discusses public Indiana appellate decisions and my previously published account of my contact records. The Pratt decision concerns court-ordered college expenses under Indiana law, not a nationwide rule about estranged adult children or ordinary child support. I haven’t interviewed the family, and I don’t know the full history behind the estrangement. Any references to my own family describe my perspective and records, not findings about anyone else’s motives or private experience. This is personal commentary, not legal advice.
Resources
Pratt v. Pratt, No. 26A-DC-1758, Indiana Court of Appeals, October 26, 2026. Seven-page nonprecedential memorandum decision. See paragraphs 2 to 12 for the timeline, testimony, text evidence and ruling.
Indiana Code § 31-16-6-2. Statute authorizing educational support orders when appropriate.
McKay v. McKay, 644 N.E.2d 164 (Ind. Ct. App. 1994). Foundational Indiana decision recognizing adult-child repudiation in the college-expense context.
Lovold v. Ellis, 988 N.E.2d 1144 (Ind. Ct. App. 2013). Applies the complete defense and explains the review standard.
Messner v. Messner, 118 N.E.3d 64 (Ind. Ct. App. 2019). Discusses conduct that begins before eighteen and continues afterward.
Koontz v. Scott, Indiana Court of Appeals, July 27, 2016. Contrasting decision finding no repudiation on a different record.
Indiana Appellate Rule 65. Explains when a memorandum decision may be cited and why other courts don’t have to follow its reasoning.