A.M. v. State of Indiana, 134 N.E.3d 361

A.M., a 15‑year‑old with a long juvenile history and special‑education needs, brutally beat a younger boy at a county fair; he later threatened the victim and was adjudicated for disorderly conduct and placed on supervised probation.
While on probation A.M. repeatedly violated terms (running away, threats, skipping school, expulsion, missed mental‑health evaluations), prompting the probation department to recommend commitment to the Department of Correction (DOC).
At a February 2018 disposition‑modification hearing A.M.’s counsel negotiated dismissal/redaction of certain allegations, avoided admissions on some charges, but A.M. admitted to battery and status offenses; counsel urged DOC placement as rehabilitative.
The juvenile court committed A.M. to the DOC for an indeterminate period; A.M. appealed claiming ineffective assistance of counsel at the modification hearing.
The Indiana Supreme Court granted transfer to decide the controlling standard for juvenile ineffective‑assistance claims at disposition modification, adopted a due‑process (not Strickland) test focused on fundamental fairness and the child’s best interests, and affirmed the commitment, finding counsel effective.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which standard governs claims of ineffective assistance of counsel in juvenile disposition‑modification hearings?	A.M.: apply Sixth Amendment Strickland (criminal standard).	State: apply Fourteenth Amendment due‑process standard used in civil/juvenile contexts.	Due‑process standard governs; Strickland does not apply.
Under the applicable standard, did A.M. receive ineffective assistance at the modification hearing?	A.M.: counsel’s remarks and strategy showed deficient advocacy and deprived him of a less‑restrictive placement.	State: counsel negotiated plea reductions, advocated candidly, and secured a procedurally fair hearing; outcome was in A.M.’s best interests.	Counsel was not ineffective; the record shows a fundamentally fair hearing and disposition consistent with A.M.’s best interests.

Kent v. United States, 383 U.S. 541 (1966) (counsels’ role described as "the essence of justice")
In re Gault, 387 U.S. 1 (1967) (juveniles have a constitutional right to counsel under the Fourteenth Amendment)
Strickland v. Washington, 466 U.S. 668 (1984) (Sixth Amendment ineffective‑assistance standard for criminal cases)
Baum v. State, 533 N.E.2d 1200 (Ind. 1989) (minimal due‑process test asking whether counsel appeared and the proceeding was procedurally fair)
Baker v. Marion Cty. Office of Family & Children, 810 N.E.2d 1035 (Ind. 2004) (adopts a "Baum‑plus" approach in termination cases: assess whether lawyer’s overall performance deprived parties of a fundamentally fair proceeding and an outcome consistent with the child’s best interests)
Bible v. State, 253 Ind. 373, 254 N.E.2d 319 (1970) (Indiana recognizes juvenile procedural rights under Fourteenth Amendment and distinguishes juvenile from criminal process)
Graves v. State, 823 N.E.2d 1193 (Ind. 2005) (applies Baum in post‑conviction contexts)