C.J. v. State of Indiana, 2017 Ind. App. LEXIS 156

At age 14–15, C.J. admitted to delinquency findings for battery and for what would be armed robbery and dangerous possession of a firearm; the juvenile court placed him on probation with suspended commitment to the DOC.
C.J. was placed at Transitions Academy (residential) for several months, then released; post-release he had violations including positive drug screens and additional petitions to modify disposition.
The State filed multiple petitions to modify disposition; after a motion to modify, the juvenile court awarded wardship to the Indiana Department of Correction, recommending a 12‑month commitment and various treatment/education programs.
C.J. filed an emergency motion to stay and sought reconsideration; the court denied relief and C.J. appealed the DOC placement.
C.J. was released from DOC in October 2016 while his appeal was pending; he argued the appeal was not moot because the DOC placement could produce negative collateral consequences.
The Court of Appeals dismissed the appeal as moot, concluding it could not provide effective relief and declining to invoke the public‑interest exception because alleged collateral consequences were speculative or unsupported.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused its discretion by placing C.J. with the DOC and whether the appeal is moot	C.J.: the commitment to DOC was an abuse of discretion; appeal is not moot because the DOC placement causes concrete collateral consequences (future dispositional arguments, aggravators, waiver to adult court, adult sentencing)	State: C.J. was released from DOC so the court cannot grant effective relief; alleged collateral consequences are speculative and do not invoke the public‑interest exception	Appeal dismissed as moot; court will not reach merits because C.J. was released and claimed collateral consequences were speculative/unsupported; no great‑public‑interest exception applied

In re M.B., 51 N.E.3d 230 (Ind. 2016) (defines mootness and when an appellate court may lack ability to provide effective relief)
In re Lawrance, 579 N.E.2d 32 (Ind. 1991) (explains the public‑interest exception to mootness)
J.B. v. Indiana Dep’t of Child Servs. (In re S.D.), 2 N.E.3d 1283 (Ind. 2014) (held collateral consequences from CHINS finding could render appeal nonmoot)
Lee v. State, 816 N.E.2d 35 (Ind. 2004) (noting that a served sentence typically renders a challenge to its validity moot)
E.L. v. State, 783 N.E.2d 360 (Ind. Ct. App. 2003) (rejects a presumption that prior DOC commitment requires recommitment on subsequent offenses)