State ex rel. J.T., 94 So. 3d 847

J.T., a sixteen-year-old juvenile, was adjudicated delinquent for resisting an officer and illegal possession of a handgun by a juvenile; dispositions were later challenged on appeal.
Officer Bissell testified he chased J.T. after a suspected encounter with a suspicious person, and J.T. discarded a loaded handgun during the pursuit.
J.T.’s sole witness contested the existence of a dispatch call or its details, suggesting potential lack of corroboration for the stop.
The trial court adjudicated delinquency and later entered dispositions that were initially concurrent but later amended to consecutive terms, extending total confinement.
On appeal, J.T. argued (i) improper continuance denial as ineffective assistance, (ii) insufficient evidence on resisting an officer, (iii) illegal/consecutive dispositions, and (iv) ineffective assistance of counsel.
The court affirmed the delinquency adjudications, vacated the dispositions, and remanded for a new disposition hearing consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of a continuance deprived counsel of adequate preparation	J.T. argues trial court abused discretion and denied effective counsel.	State contends continuance denial proper given prior delays and available disclosures.	No reversible error; no prejudice shown; continuance denial affirmed.
Sufficiency of evidence to support resisting an officer	J.T. contends lack of reasonable suspicion and improper detention.	State contends officer had reasonable suspicion and J.T. fled, constituting obstruction.	Sufficient evidence; detention lawful; flight violated 14:108.
Legality of dispositions; consecutive vs concurrent sentencing	Dispositions improperly exceed statutory and case-law limits and should be concurrent.	Dispositions could be consecutive under statute and Supreme Court precedent.	Consecutive dispositions improper; must be concurrent and within six months total; dispositions vacated and remanded.
Ineffective assistance of counsel	Counsel failed to file motions (suppress, new trial, post-disposition) impacting outcome.	Record does not demonstrate prejudice; no reversible error.	No reversible ineffectiveness; claims rejected; issues resolved on other grounds.

State in the Interest of B.J., 906 So.2d 392 (La. 2005) (limits concurrent misdemeanor dispositions to six months in juvenile cases)
State in the Interest of P.L., 81 So.3d 983 (La. App. 4th Cir. 2012) (abandoned handgun search upheld when reasonable suspicion existed)
Porche, 780 So.2d 1156 (La. 2001) (continuance denial may be reversible where lack of preparation prejudices defense)
Laugand, 759 So.2d 34 (La. 2000) (unprepared counsel may entitle defendant to relief; strong prejudice showing required)
State v. Addison, 657 So.2d 974 (La. 1995) (last-minute substitution of counsel can be reversible error when prejudicial)
Tucker, 626 So.2d 707 (La. 1993) (stop and seizure analysis; seizure requires virtually certain detention)
State v. Reeves, 11 So.3d 1031 (La. 2009) (trial court discretion in juvenile proceedings reviewed for abuse)
State v. Edwards, 530 So.2d 97 (La. App. 4th Cir. 1988) (evidence suppression considerations for abandoned contraband under improper detention)
State v. Knowles, 40,324 (La. App. 2 Cir. 2005) (defendant must know of arrest or impending detention for 14:108 conviction)