R.R. v. State of Indiana, 106 N.E.3d 1037

R.R., a juvenile placed on probation after admitting misdemeanor criminal mischief, faced multiple probation-modification petitions and a September 2016 petition alleging auto theft and false informing.
A "Request for Taking Child Into Custody" was filed in January 2017 based on the September petition.
On Feb. 7, 2017, the court held a fact-finding hearing on the September petition; R.R. was not present, though his mother and counsel were. Counsel requested a continuance; the court denied it and proceeded.
The court found R.R. delinquent for auto theft and false informing; later he was taken into custody and made a ward of the Department of Correction.
The Court of Appeals held R.R. had waived his right to appear by knowingly refusing to appear; the Indiana Supreme Court granted transfer, vacated that opinion, and reversed the delinquency finding for statutory waiver defects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juveniles have a due-process right to be present at fact-finding (adjudicatory) hearings	R.R.: juveniles have a due-process right to be present.	State: generally conceded on this record but argued waiver could be found by nonappearance.	Assumed (without deciding) that juveniles have the right.
Whether R.R. waived the right to be present by failing to appear	R.R.: no waiver—statute prescribes specific waiver methods and none were satisfied.	State: nonappearance should suffice to find waiver to prevent gamesmanship.	Waiver did not occur; statutory waiver requirements not met.
Proper interpretation/scope of Indiana's juvenile waiver-of-rights statute (I.C. § 31-32-5-1)	R.R.: statute requires one of three enumerated waiver methods; no-show is not among them.	State: literal reading leads to absurd results; courts should apply absurdity doctrine or infer waiver.	Statute governs; only the three listed waiver methods apply; court may not judicially add a fourth.
Whether the absurdity doctrine allows courts to read a nonappearance waiver into the statute	R.R.: not applicable; do not rewrite statute.	State: legislative scheme would be unworkable if juveniles can evade hearings by not appearing.	Absurdity doctrine inapplicable; would require substantive judicial rewrite; decline to apply.

Lewis v. State, 259 Ind. 431, 288 N.E.2d 138 (juvenile confession waiver requirements and right-to-consult with parents/attorney)
Bible v. State, 253 Ind. 373, 254 N.E.2d 319 (state courts may independently examine constitutional questions)
Jackson v. State, 868 N.E.2d 494 (adult defendants may waive presence by failing to appear)
Garner v. Kempf, 93 N.E.3d 1091 (statutory interpretation: apply plain meaning)
Calvin v. State, 87 N.E.3d 474 (absurdity doctrine is narrow, "strong medicine")
B.A. v. State, 100 N.E.3d 225 (discussion of Lewis being superseded by statute as to certain points)
McKeiver v. Pennsylvania, 403 U.S. 528 (due process in juvenile proceedings requires fundamental fairness)