State ex rel. R.P., 150 So. 3d 76

R.P. was adjudicated delinquent for illegal possession of a handgun by a juvenile under La. R.S. 14:95.8.
Sentence: six months in DOC with three months suspended and credit for time served.
Judgment ordered active parole for three months upon release; appellate review followed.
Evidence indicated a handgun was recovered from a backpack worn by R.P. during the incident.
Officers testified the backpack contained the handgun and was worn on R.P.’s back throughout the event.
Court amended the disposition to three months of active probation, not active parole, and remanded for custody-order amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence R.P. possessed a handgun on his person?	State argues evidence showed possession since backpack with handgun was on R.P.	R.P. argues handgun not on his person; constructive possession insufficient	Yes; handgun on R.P. (backpack on his back) satisfied possession element.
Was R.P. under seventeen at the time of the offense?	State established age from booking records and birth date in multiple filings.	R.P. did not present contrary evidence; age not contested	Yes; R.P. was under seventeen.
Was the sentencing disposition properly characterized as active parole?	State contends the court imposed valid disposition.	Disposition titled active parole; improper under statute	Amended to three months active probation; remanded to amend custody minutes.

State ex rel. TM, 88 So.3d 1234 (La.App. 4 Cir. 2010) (construction of on/about a person; possession standards in juvenile cases)
State in the Interest of KM., 49 So.3d 460 (La.App. 4 Cir. 2010) (knapsack/handbag possession as on the person)
State in the Interest of J.J., 125 So.3d 1248 (La.App. 4 Cir. 2013) (appellate standard in juvenile cases; proof beyond reasonable doubt)
Jackson v. Virginia, 443 U.S. 307 (1981) (standard for sufficiency of evidence in criminal/juvenile contexts)