E.H. v. State of Indiana (mem. dec.), 57A05-1708-JV-2047

In fall 2016 school investigation, students reported buying marijuana from 16‑year‑old E.H.; a search of his home uncovered large quantities of marijuana, scales, paraphernalia, and wax marijuana in his bedroom.
E.H. admitted buying a pound at a time, breaking it into quarter‑pound amounts to resell, and selling to numerous customers (including juveniles); he estimated ~6 months of selling and provided buyers’ names.
Dec. 14, 2016: State filed delinquency petition alleging what would be (1) Level 5 felony dealing in marijuana, (2) Class B misdemeanor possession, (3) Class C misdemeanor possession of paraphernalia.
July 5, 2017: E.H. admitted to conduct amounting to Level 5 felony dealing; he was placed on home detention until disposition.
While on home detention he minimally complied, tested positive for methamphetamine/amphetamine, denied having a substance problem, and told his probation officer he would “do what I want.”
At disposition the juvenile probation officer recommended commitment to DOC (Indiana Boys’ School) based on offense seriousness, drug use, noncompliance, and community safety; the juvenile court committed E.H. to DOC. Court of Appeals affirmed.

Issue	E.H.’s Argument	State’s Argument	Held
Whether commitment to DOC (Indiana Boys’ School) was an abuse of discretion as a more restrictive placement than required by statute	Commitment was improper because a less restrictive option (home detention/community supervision) was available	Commitment appropriate given seriousness and scope of dealing, juvenile buyers, E.H.’s noncompliance on home detention, positive drug screen, denial of substance problem, and prior probation referrals	Court affirmed: no abuse of discretion — restrictive placement justified by community safety, best interest of child, and failure of less restrictive measures

J.S. v. State, 881 N.E.2d 26 (Ind. Ct. App. 2008) (juvenile court disposition reviewed for abuse of discretion and must consider statutory placement factors)
E.L. v. State, 783 N.E.2d 360 (Ind. Ct. App. 2003) (standard for reversal of juvenile court disposition)
C.C. v. State, 831 N.E.2d 215 (Ind. Ct. App. 2005) (juvenile court’s discretion is subject to welfare, community safety, and least‑harsh‑disposition policy)
C.T.S. v. State, 781 N.E.2d 1193 (Ind. Ct. App. 2003) (juvenile court afforded wide latitude in dispositional matters)
K.A. v. State, 775 N.E.2d 382 (Ind. Ct. App. 2002) (statute permits more restrictive placement when in child’s best interest or community safety requires it)