In the Interest Of: Mf v. The State of Wyoming, 2013 WY 104

MF was adjudicated a child in need of supervision (CHINS) after admitting truancy, school discipline, and home conduct allegations while 15.
Initial disposition: six months juvenile probation following May 2012 adjudication.
Two probation revocations (Sept. 2012 and Jan. 2013) resulted in placement in residential programs and extensions of supervised probation.
In January 2013 the juvenile court ordered MF remain in DFS custody and on probation until his 18th birthday; MF appealed.
The statutory question centers on Wyo. Stat. § 14-6-431(b), which states CHINS orders "shall terminate" when the child reaches 17, then adds that "services may be provided on a case by case basis."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court may extend CHINS jurisdiction/conditions beyond a child's 17th birthday	CHINS orders must terminate at 17; court lacked authority to impose conditions past 17	The second sentence of § 14-6-431(b) permits DFS services "on a case by case basis," which lets the juvenile court retain jurisdiction to order continued DFS custody/services past 17	The court held § 14-6-431(b) unambiguously requires CHINS orders terminate at 17; juvenile court lacked authority to impose CHINS conditions beyond 17; DFS may provide voluntary services post-17 but court jurisdiction does not continue

Rock v. Lankford, 301 P.3d 1075 (Wyo. 2013) (standards and principles of statutory interpretation)
Redco Construction Co. v. Profile Props., LLC, 271 P.3d 408 (Wyo. 2012) (statutory construction in pari materia and plain-language rules)
DeLoge v. Homar, 297 P.3d 117 (Wyo. 2013) (jurisdictional issues reviewed de novo)
In re DCP, 30 P.3d 29 (Wyo. 2001) (equitable jurisdiction cannot override statutory language)
In re Hartt's Estate, 295 P.2d 985 (Wyo. 1956) (principle limiting equitable jurisdiction over explicit statutes)