A.H. v. State of Indiana (mem. dec.), 90A04-1705-JV-1038

In May 2013 the State petitioned that 13‑year‑old A.H. was delinquent for multiple inappropriate sexual touches of female classmates; the juvenile court adjudicated him delinquent on three counts.
The court placed A.H. on 18 months’ probation and, over the following years, moved him through a series of progressively restrictive placements (including George Junior Republic, Resolute, and Pierceton Woods Academy) and held multiple review hearings and emergency residence changes.
In June 2016 the court placed A.H. at Pierceton Woods for sex‑offender treatment expected to last 9–12 months; treatment required full disclosure and successful polygraph proof of disclosure.
A.H. failed two polygraphs, continued to exhibit inappropriate touching while in treatment, was not completing assignments reliably, and the treatment team doubted he would significantly improve with more time.
After a dispositional review, the trial court moved A.H. from Pierceton Woods to the Department of Correction, concluding less‑restrictive options had been unsuccessful and public safety/rehabilitation concerns justified a more restrictive placement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused its discretion by placing A.H. in the Department of Correction	A.H.: Pierceton Woods was the least restrictive appropriate setting; he had therapeutic rapport and family could engage in therapy there	State: Less‑restrictive placements had failed; A.H. was not progressing, continued offending, and posed rehabilitation/public safety concerns	No abuse of discretion; DOC placement was within court's broad discretion

R.H. v. State, 937 N.E.2d 386 (Ind. Ct. App. 2010) (distinguishes juvenile process purpose—rehabilitation—not criminal punishment)
Jordan v. State, 512 N.E.2d 407 (Ind. 1987) (juvenile courts have a range of placement options from family homes to state institutions)
D.E. v. State, 962 N.E.2d 94 (Ind. Ct. App. 2011) (appellate review of juvenile dispositional choice is for abuse of discretion; placement at DOC permissible where less‑restrictive options failed)