J.D.M. v. State of Indiana, 2017 Ind. LEXIS 106

J.D.M., born 1996, was adjudicated delinquent for acts that as an adult would be Class C felony child molestation after an incident with a nine‑year‑old when he was 15.
He was placed at Wernle Youth and Family Treatment Center for sexually maladaptive treatment and remained there through multiple review hearings into his 18th year.
The juvenile court deferred formal placement on probation pending completion of treatment; the dispositional order continued placement at Wernle and did not state J.D.M. was on probation.
The court held sex‑offender registry hearings while J.D.M. remained in Wernle; experts’ risk assessments decreased over time (from "high" to "low‑to‑moderate").
On September 8, 2015 the juvenile court ordered J.D.M. to register as a sex offender; the order was appealed to the Court of Appeals, which affirmed, and this Court granted transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile could be ordered to register before discharge from Wernle	J.D.M.: registration prerequisites not met because he was not on probation nor discharged from a secure facility	State: Probation dept. had responsibility for placement so he was effectively on probation; release/placement on probation was imminent and hearing need not wait	Court: Reversed — court must expressly find one of the §11‑8‑8‑5(b)(2)(B) conditions (on probation or discharged from covered facility) and cannot order registration while juvenile remains in treatment absent such a finding

N.L. v. State, 989 N.E.2d 773 (Ind. 2013) (juvenile registry order requires an evidentiary hearing, clear and convincing finding that juvenile likely to reoffend, and express findings; informal continuations are insufficient)
J.C.C. v. State, 897 N.E.2d 931 (Ind. 2008) (registry hearing for juveniles in secure placement must wait until after release so rehabilitation can be assessed)