D.J. v. State of Indiana, 49A05-1704-JV-673

Four juveniles (including D.J., age 12) confronted four children in an apartment stairwell; one juvenile produced a gun, demanded phones/money, and took phones from R.R. and D.M. before all four fled.
D.J. was seen near the scene shortly after; initially detained unarmed, released, then arrested after victims identified him.
State charged D.J. in juvenile court with two counts of armed robbery and two counts of criminal confinement (Level 3 felonies if adults).
At the fact-finding hearing D.J. admitted presence but denied participation; the juvenile court made true findings on all four counts and adjudicated him delinquent.
On appeal, D.J. argued (1) double jeopardy barred multiple true findings in a single delinquency adjudication and (2) the evidence was insufficient to prove accomplice liability.
The Court of Appeals affirmed the armed-robbery adjudications, reversed and vacated the criminal-confinement findings as violating the Indiana Constitution’s Double Jeopardy Clause, and remanded to vacate those findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether multiple true findings (armed robbery and criminal confinement) violate Indiana double jeopardy	State: double jeopardy does not apply because juvenile proceedings produce a single delinquency adjudication	D.J.: double jeopardy applies; multiple true findings may be used to enhance later penal consequences	Court: Double jeopardy applies under Indiana Constitution; confinement findings vacated because same evidentiary facts supported both offenses
Whether evidence was sufficient to support accomplice liability for armed robbery	State: D.J. aided the robbery by scouting, remaining with co-actors, failing to oppose, and fleeing with them	D.J.: he was present but did not participate; his testimony claimed he was deceived or coincidentally present	Court: Sufficient evidence of accomplice liability (presence, companionship, failure to oppose, conduct before/during/after) to support armed-robbery adjudication

D.B. v. State, 842 N.E.2d 399 (Ind. Ct. App. 2006) (vacating overlapping juvenile findings where single act supported multiple charges)
H.M. v. State, 892 N.E.2d 679 (Ind. Ct. App. 2008) (holding double jeopardy principles apply to juvenile multiple true findings)
Richardson v. State, 717 N.E.2d 32 (Ind. 1999) (establishing statutory-elements and actual-evidence tests for double jeopardy)
Wieland v. State, 736 N.E.2d 1198 (Ind. 2000) (discussing application of Richardson tests)
Vanzandt v. State, 731 N.E.2d 450 (Ind. Ct. App. 2000) (vacating robbery + confinement convictions where confinement was incidental to robbery)
Polk v. State, 783 N.E.2d 1253 (Ind. Ct. App. 2003) (same-offense analysis where single confrontation produced robbery and confinement)
Garland v. State, 788 N.E.2d 425 (Ind. 2003) (listing factors relevant to accomplice liability)
Wright v. State, 828 N.E.2d 904 (Ind. 2005) (standard of review for sufficiency of the evidence)