R.P. v. State, 151 So. 3d 204

J.P., a minor, spent 103 days in a juvenile detention facility and 30 more in jail after turning 18, without ever being adjudicated delinquent.
In 2011, D.O. was ordered to pay $650 for J.P.’s detention after a contempt-like proceeding with no petition for delinquency filed.
In 2012, J.P. was detained for 133 days pending adjudication; no adjudicatory hearing or timely petition was held and no record supported the charges.
The court transferred J.P. to Jefferson Davis County Jail at age 18 and never set a proper adjudicatory hearing; after lengthy proceedings, J.P. was released.
The trial court ultimately ordered the parents to pay approximately $9,380 in detention costs, which the Mississippi Supreme Court reversed and rendered for the parents.
The court held that the State cannot charge parents for detention costs when the child has not been adjudicated delinquent and when detention was unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May courts charge parents for detention costs without delinquency adjudication?	D.O./R.P. contend costs were improper.	State argues statute allowed costs regardless of adjudication.	No; costs improper without adjudication.
Did misapplication of Section 43-21-615/613 violate due process?	Procedures violated by lack of petition and notice.	Procedures satisfied by appearances and continuances.	Yes; due process violated; improper notice and procedure cannot sustain costs.
Was J.P.’s 2012 detention lawful under Youth Court Law?	Detention proceeded despite no adjudication and improper petition.	Detention justified as contempt and discretionary under statute.	Detention unlawful; no authority to detain without adjudication.
Did the 2012/2011 procedures comply with notice, transcripts, and recordkeeping requirements?	Record lacking; due process not safeguarded.	Proceedings imperfect but sufficiently noticed.	Procedures deficient; invalid basis to impose costs.

In Interest of Dennis, 291 So.2d 731 (Miss.1974) (commitment requires adjudication and proper petition)
In Interest of B.D., 720 So.2d 476 (Miss.1998) (due process safeguards for restitution in youth cases)
A.B. v. Lauderdale County Dep’t of Human Servs., 13 So.3d 1263 (Miss.2009) (appellate review standards for youth court proceedings)
M.R.L. v. State, 488 So.2d 788 (Miss.1986) (dominant parental right to custody; strict burden for delinquency findings)
Hopkins v. Youth Court of Issaquena County, 227 So.2d 282 (Miss.1969) (parents must be summoned to youth court proceedings)
In Re Gressett, 272 So.2d 921 (Miss.1973) (due process protections for juveniles similar to adults)