In the Interest of: J.R., a Minor
2294 EDA 2015
| Pa. Super. Ct. | Nov 16, 2016Background
- J.R., born May 1995, was adjudicated delinquent in April 2008 after admitting to misdemeanor indecent assault and committed to a secure juvenile facility under 42 Pa.C.S. § 6353(a).
- Statute limited juvenile commitment to the lesser of four years or the adult maximum; indecent assault carried a five-year adult maximum.
- J.R. remained in custody over seven years; the juvenile court held multiple review hearings and transferred him among facilities to meet rehabilitative needs.
- In May 2015, counsel filed a habeas corpus petition; the trial court granted release in June 2015, vacated, then again granted habeas relief on July 10, 2015.
- The Commonwealth appealed, arguing the trial court erred because review hearings (with notice and counsel) properly extended the commitment under § 6353 and no separate Commonwealth application was required.
- J.R. contended the Commonwealth failed to prove a valid modification at the review hearings and that the appeal was moot because he turned 21 in May 2016, terminating juvenile court jurisdiction.
Issues
| Issue | Commonwealth's Argument | J.R.'s Argument | Held |
|---|---|---|---|
| Whether habeas relief was improper because review hearings extended J.R.’s juvenile commitment under 42 Pa.C.S. § 6353 | Review hearings (with notice and counsel) sufficed to continue/modify the commitment; no Commonwealth application required | Commonwealth failed to prove a lawful modification at the review hearings; habeas relief was proper | Appeal dismissed as moot because J.R. turned 21 and juvenile court lost jurisdiction; court declined to address the substantive claim |
Key Cases Cited
- Deutsche Bank Nat. Co. v. Butler, 868 A.2d 574 (Pa. Super. 2005) (mootness doctrine and requirement of an actual case or controversy)
- Rivera v. Pennsylvania Department of Corrections, 837 A.2d 525 (Pa. Super. 2003) (courts should not issue purely advisory opinions)
- Commonwealth v. Smith, 486 A.2d 445 (Pa. Super. 1984) (appeals dismissed when events prevent the court from granting relief)
- Public Defender’s Office of Venango County v. Venango County Court of Common Pleas, 893 A.2d 1275 (Pa. 2006) (exceptions to mootness: capable of repetition yet evading review, public interest, or detriment without a decision)