In re J.T., 252 A.3d 1276

BHDDH petitioned to retain J.T., a person with developmental disabilities, at a JRI group home after his 2008 release from the Rhode Island Training School following juvenile adjudications for sexual offenses.
J.T. initially stayed voluntarily; BHDDH obtained court retention orders beginning in 2009; a July 2019 order was vacated, but new retention petitions followed in Sept. 2019 and Sept. 2020.
At a September 25, 2020 hearing, Dr. Daniel Manfra (psychiatry expert) testified J.T. has intellectual disability with marked adaptive deficits, poor planning, medication noncompliance, and poses serious risk without 24-hour supervision.
The District Court found by clear and convincing evidence that J.T. is developmentally disabled and that unsupervised community presence would likely cause serious harm; it ordered J.T. to return to the group home and restricted leaving without facility permission.
J.T. appealed, arguing (1) he was entitled to a de novo appeal in Superior Court under § 40.1-22-10(f), and (2) the court erred in considering his juvenile adjudication, sex‑offender registration, and uncharged misconduct in assessing disability and risk.
The Supreme Court heard the matter and affirmed the District Court, ruling the appeal lies to the Supreme Court and that the evidentiary objections were waived.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Forum for de novo appeal and timeliness under § 40.1-22-10(f)	Appeal must be heard de novo in Superior Court	§ 40.1-22-10(f) permits appeal to the court having appellate jurisdiction — the Supreme Court	The statute is ambiguous but the only court of appellate jurisdiction is the Supreme Court; appeal to this Court was timely (filed 11 days after order)
Admissibility/use of juvenile adjudication, sex‑offender registration, and uncharged misconduct	District Court erred in considering juvenile adjudication, registration, and uncharged acts in determining disability and risk	Evidence was received at hearing; respondent failed to preserve objections; some facts conceded on cross	Objections were waived under raise‑or‑waive; respondent conceded registration on cross; District Court decision affirmed

Crenshaw v. State, 227 A.3d 67 (R.I. 2020) (statutory interpretation reviewed de novo)
Latham v. State Department of Education, 355 A.2d 400 (R.I. 1976) (appeal timeframe: absent statute, appeals must be filed within a reasonable time; laches doctrine)
Balmuth v. Dolce for Town of Portsmouth, 182 A.3d 576 (R.I. 2018) (ambiguous statutory language construed using maxims of construction)
Selby v. Baird, 240 A.3d 243 (R.I. 2020) (raise‑or‑waive rule; appellate courts generally will not consider issues not raised below)