L.F., Appellant-Defendant v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] After L.F. was twice adjudicated delinquent within a three-month span, the trial court committed him to the Indiana Department of Correction (“DOC”). L.F. now appeals, contending the trial court abused its discretion by doing so. We affirm.

Facts and Procedural History

[2] In January 2024, then fifteen-year-old L.F. led police on a high-speed pursuit in response to law enforcement's attempt to conduct a traffic stop. While fleeing, L.F. drove at speeds of more than ninety miles per hour and committed several traffic violations. After a few minutes, L.F. stopped, exited his truck, and was apprehended by police. During a pair of searches, police found a vape device on L.F.’s person and marijuana in L.F.’s truck. L.F. had never obtained a driver's license and was under the influence of marijuana throughout the chase. Based on these events, the State alleged L.F. was delinquent.¹

[3] A few months later, L.F. was in a vehicle with several other juveniles, marijuana, alcohol, and “two glass bongs.” Appellant's App. Vol. 2 at 140. The State moved to amend its delinquency petition to add allegations for Class B misdemeanor possession of marijuana and Class C misdemeanor possession of paraphernalia, if committed by an adult. In April, L.F. admitted to the delinquency allegations and the trial court adjudicated him delinquent. The trial court placed L.F. on probation for six months, suspended his license for one year,² and required him to complete a substance abuse evaluation, among other probation conditions.

[4] In late May—while he was still on probation—L.F. and his cousin met three other juveniles to trade one gun for another. The transaction did not go according to plan. Rather than receiving the anticipated gun, L.F. was handed a bag containing a toy gun and raw macaroni. Realizing he had been duped, L.F. and his cousin drove after the other juveniles. Sometime in the brief pursuit, the other juveniles began firing rifles out the windows of their car toward L.F. and his cousin. L.F.’s cousin—the vehicle's driver—was struck by a bullet near his shoulder. After briefly stopping, L.F. and his cousin once more gave chase. Eventually, their car struck a deer and crashed. Police arrived on scene where L.F. was “very intoxicated and very belligerent with law enforcement.” Tr. Vol. 2 at 27.

[5] Soon after, the State moved to modify the April dispositional decree, alleging L.F. violated the terms of his probation. The State also filed another delinquency petition, claiming L.F. committed Class A misdemeanor dangerous possession of a firearm and Class C misdemeanor minor consuming alcohol. In June, L.F. admitted to the allegations in the most recent delinquency petition and to violating the terms and conditions of his probation. The trial court adjudicated L.F. delinquent and committed him to the DOC, reasoning, in part, L.F. “continues to commit delinquent acts that pose a risk of harm to himself and the community ․ that are increasing in severity.” Appellant's App. Vol. 2 at 53.

The trial court did not abuse its discretion by committing L.F. to the DOC.

[6] “Juvenile courts enjoy significant discretion in crafting an appropriate disposition for juveniles found delinquent.” B.K. v. State, 235 N.E.3d 142, 143 (Ind. 2024). We therefore review a disposition for abuse of discretion, which occurs when a trial court misinterprets the law or issues a decision clearly contravening the logic and effect of the facts and circumstances before it. G.W. v. State, 231 N.E.3d 184, 188 (Ind. 2024). In conducting this review, we neither reweigh evidence nor judge witness credibility. A.F. v. State, 247 N.E.3d 841, 843 (Ind. Ct. App. 2024).

[7] Although provided with “wide latitude and great flexibility” when fashioning an appropriate disposition, R.G. v. State, 212 N.E.3d 720, 723 (Ind. Ct. App. 2023) (citation omitted), a trial court must consider several factors while doing so:

If consistent with the safety of the community and the best interest of the child, the juvenile court shall enter a dispositional decree that:

(1) is:

(A) in the least restrictive (most family like) and most appropriate setting available; and

(B) close to the parents’ home, consistent with the best interest and special needs of the child;

(2) least interferes with family autonomy;

(3) is least disruptive of family life;

(4) imposes the least restraint on the freedom of the child and the child's parent, guardian, or custodian; and

(5) provides a reasonable opportunity for participation by the child's parent, guardian, or custodian.

Ind. Code § 31-37-18-6 (1997); see also M.C. v. State, 134 N.E.3d 453, 458 (Ind. Ct. App. 2019) (describing the trial court's discretion as “subject to the statutory considerations of the welfare of the child, the safety of the community, and the policy of favoring the least harsh disposition”), trans. denied, cert. denied. Ultimately, commitment to the DOC “should be treated as a last resort.” G.W., 231 N.E.3d at 190 (quoting C.H. v. State, 201 N.E.3d 202, 205 (Ind. Ct. App. 2022)).

[8] Despite acknowledging his acts “had a huge potential ․ to inflict[ ] much greater harm than what occurred[,]” L.F. claims the trial court abused its discretion by committing him to the DOC because “a more appropriate disposition ․ would have been to place him in a residential treatment facility.” Appellant's Br. at 20, 14. As L.F. suggests, a less restrictive setting was available. But Indiana Code Section 31-37-18-6 requires placement in the least restrictive setting only “[i]f consistent with the safety of the community and the best interest of the child.” Here, the trial court “considered residential treatment,” but ultimately placed L.F. in the DOC because “L.F. has demonstrated an unwillingness to follow the rules of probation and address his substance abuse and mental health issues by engaging in criminal and reckless behavior that is not only self-destructive but puts those close to him and the general public at risk of harm.” Appellant's App. Vol. 2 at 53–54. Said another way, the trial court recognized less restrictive rehabilitative efforts had failed to alter L.F.’s behavior. After all, L.F. was on probation for a prior delinquency adjudication when he partook in the gun trade gone awry and subsequent car chase, all while under the influence of alcohol. In the end, the trial court adhered to the statutory scheme and determined L.F.’s escalating delinquent behavior posed a threat to himself and his community such that a less restrictive placement was not in his best interest.³

Conclusion

[9] The trial court did not abuse its discretion by committing L.F. to the DOC.

[10] Affirmed.

FOOTNOTES

1.   Specifically, the State alleged L.F. committed the following acts that would be crimes if committed by an adult: Level 6 felony resisting law enforcement; Class C misdemeanor operating a motor vehicle without ever receiving a license; Class A misdemeanor operating a vehicle while intoxicated endangering a person; Class C misdemeanor operating a vehicle with a Schedule I or II controlled substance or its metabolite in the blood; Class C misdemeanor reckless driving; and Class B misdemeanor possession of marijuana.

2.   The trial court suspended L.F.’s driving privileges even though he was not eligible to receive a driver's license at the time, thereby increasing the potential penalty if L.F. drove.

3.   To the extent L.F. claims the trial court “put too much emphasis on the recommendation of commitment to DOC made by Probation,” Appellant's Br. at 19, he invites us to reweigh evidence. Our standard of review precludes us from doing so. See A.F., 247 N.E.3d at 843.

Kenworthy, Judge.

Mathias, J., and Brown, J., concur.