Byron D. Harris, Jr. v. State of Indiana, 148 N.E.3d 1107

Defendant Byron D. Harris, Jr. (born Jan. 2003) was charged as an adult with attempted murder after firing multiple shots at Trestepfone Pryor in an apartment complex; Pryor suffered two gunshot wounds.
Juvenile court waived jurisdiction to adult court based on Harris’s extensive juvenile record and risk to public safety; Harris was 16 at trial.
Before jury selection the State obtained a witness-separation order; Harris’s mother, Twanna Warren, was listed as a State witness and was excluded from the courtroom under that order.
Harris objected (noting his juvenile status and that his mother wanted to be present); the trial court overruled the objection, but the State never called Warren to testify; jury convicted Harris of attempted murder.
On appeal Harris argued the exclusion violated his due process/right to meaningful parental consultation; the Court of Appeals held the juvenile’s parent (even after waiver to adult court) qualifies under Evidence Rule 615(c) as "essential," reversed, and remanded because the State did not rebut the presumption of prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exclusion of a waived-juvenile's parent from trial under a witness-separation order violated due process	The State relied on Rule 615 separation authority in adult court and on traditional limits of Rule 615 exceptions	Harris argued his youth means he needs meaningful parental consultation during trial and exclusion denied due process	Majority: Reversed — parent of a juvenile waived to adult court is "essential" under Evid. R. 615(c); exclusion was error and not shown harmless
Whether the claim/Rule 615(c) issue was preserved for appeal	State/dissent: Harris failed to raise constitutional or Rule 615(c) arguments at trial and thus waived them	Harris: He specifically objected to exclusion of his parent and cited his juvenile status, preserving the issue	Majority: Found preservation adequate and reached merits; dissent would find waiver and affirm

Long v. State, 743 N.E.2d 253 (Ind. 2001) (explains Rule 615 purpose and narrow construction of the “essential” witness exception)
Hernandez v. State, 716 N.E.2d 948 (Ind. 1999) (example of ‘‘essential’’ witness where only person could assist cross-examination)
Osborne v. State, 754 N.E.2d 916 (Ind. 2001) (trial-court discretion in applying Rule 615 exceptions; exceptions should be narrowly construed)
K.S. v. State, 849 N.E.2d 538 (Ind. 2006) (parent is a party in juvenile proceedings and thus not subject to separation in those proceedings)
R.R. v. State, 106 N.E.3d 1037 (Ind. 2018) (framework for deciding juvenile-related constitutional questions not directly addressed by U.S. Supreme Court)
D.D.B. v. State, 691 N.E.2d 486 (Ind. Ct. App. 1998) (meaningful consultation requirement between juvenile and parent/guardian for rights decisions)
S.D. v. State, 937 N.E.2d 425 (Ind. Ct. App. 2010) (juveniles’ special status relevant in criminal procedure)
Miller v. Alabama, 567 U.S. 460 (2012) (recognizes juveniles’ diminished culpability and special constitutional considerations)
J.D.B. v. North Carolina, 564 U.S. 261 (2011) (child’s age is relevant to custodial-interrogation analysis; juveniles differ from adults)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles cannot be sentenced to death; highlights differences between juveniles and adults)