M.D. v. State of Indiana (mem. dec.)
20A03-1706-JV-1399
| Ind. Ct. App. | Nov 20, 2017Background
- May 23, 2016: State filed delinquency petition (Cause No. 225) charging M.D. with multiple offenses (burglary counts, intimidation, resisting law enforcement). Court noted M.D. was at DOC when petition filed.
- December 2016–February 2017: M.D. admitted to several counts across two related juvenile cases (Cause No. 8 and Cause No. 225); court placed him on probation with conditions including electronic monitoring, therapy, drug screens, education, and VORP.
- January 2017: Electronic monitoring was lifted after satisfactory progress; later reinstated in April 2017 following noncompliance.
- March–May 2017: Probation officer reported multiple violations (missed meetings, leaving home without permission, positive marijuana screen, failure to meet school-hour requirements).
- May 18, 2017: After repeated violations and unsuccessful rehabilitative efforts, the juvenile court found removal from the home in M.D.’s and the community’s best interest, adjudicated him a ward of the DOC, and committed him to Logansport Juvenile Facility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Court jurisdiction to approve filing and proceed | State: Court had subject-matter and personal jurisdiction; M.D. waived procedural challenge by not objecting below | M.D.: Court lacked jurisdiction because time limits weren’t met and prior DOC jurisdiction precluded juvenile court action | Court: Jurisdiction existed; procedural objections were waived by failure to object; appeal is collateral attack not jurisdictional |
| Whether commitment to DOC was an abuse of discretion / least-restrictive placement | State: Court provided individualized services; M.D. repeatedly violated lenient placements, justifying DOC commitment | M.D.: Violations (electronic monitor perimeter, missed probation meetings, incomplete school hours) didn’t merit DOC; placement wasn’t least restrictive | Court: No abuse of discretion; given prior efforts and continued violations, DOC placement was consistent with child’s best interest and community safety |
Key Cases Cited
- K.S. v. State, 849 N.E.2d 538 (Ind. 2006) (distinguishes subject-matter and personal jurisdiction from procedural error and rejects collateral attack where procedural objections were not timely raised)
- J.D. v. State, 859 N.E.2d 341 (Ind. 2007) (statutory least-restrictive-placement requirement applies only when consistent with community safety and child’s best interest)
- J.S. v. State, 881 N.E.2d 26 (Ind. Ct. App. 2008) (standard of review: disposition is within juvenile court’s broad discretion; reversal only for abuse of that discretion)