D.C., Appellant-Respondent v. STATE (2025)

MEMORANDUM DECISION

[1] D.C. appeals only the portion of the trial court's dispositional decree ordering him to serve fourteen days in the Allen County Juvenile Center (“ACJC”). D.C. argues the trial court's placement decision was an abuse of discretion and failed to contain necessary findings to support placement in secured detention. The State argues that we must dismiss the case as moot, pointing out that D.C. has already served his fourteen days in the ACJC.¹ Because we conclude the case is moot, we dismiss.²

Facts and Procedural History

[2] On March 18, 2024, the State filed a juvenile delinquency petition alleging that D.C. committed the following alleged offenses, which if committed by an adult would be: Level 6 felony battery against a public safety official; Class A misdemeanor domestic battery; Class B misdemeanor disorderly conduct; and Class C misdemeanor minor consuming alcohol.

[3] A fact-finding hearing was held October 23, 2024. The trial court took the matter under advisement and, on November 6, 2024, entered an order determining D.C. committed the alleged conduct. A dispositional hearing was held on November 21, 2024. Appellant's App. Vol. 2 p. 11.

[4] During the hearing, the trial court heard testimony from D.C., his parents, a guardian ad litem, and a representative from the probation department. Defense counsel requested that “the Court accept th[e] recommendation that [D.C.] be involved in the term of probation, that he be allowed, and authorized, to move to the State of Kentucky.” Tr. Vol. 2 p. 6. At one point, the trial court asked D.C. “[h]ow would you do today on a drug screen, if you were given one[ ],” and D.C. responded that he would “[f]ail.” Id. at 7. D.C. later admitted to using marijuana and stealing the marijuana from a friend. See id. at 7, 9.

[5] After a brief recess, the trial court found that “number one, substance abuse use is troubling, however, substance abuse the night before you come to Court, is, is absolutely disdain for the Court and it's thumbing your nose at the authority of the Court, and the seriousness of these proceedings. And it will not happen on my watch.” Id. at 13. The trial court then ordered that D.C. be placed in secure detention at the ACJC for fourteen days, i.e., until December 3, 2024. In addition to the secure detention, the trial court also ordered a one-year term of probation supervision that included completion of twenty hours of community service, obtaining a substance abuse evaluation and completing any recommended follow up treatment, and authorization to relocate to Kentucky. See id. The trial court then issued its written Dispositional Order dated November 21, 2024. D.C. now appeals.

Discussion and Decision

[6] D.C. only challenges that portion of the trial court's dispositional decree that placed D.C. in secure detention at the ACJC for a term of fourteen days. It is undisputed that D.C. has completed his fourteen days of secure detention and has been released from the ACJC. “Mootness arises when the primary issue within the case has been ended or settled, or in some manner disposed of, so as to render it unnecessary to decide the question involved.” In re Custody of M.B., 51 N.E.3d 230, 233 (Ind. 2016) (internal quotation omitted) (quoting Matter of Lawrance, 579 N.E.2d 32, 37 (Ind.1991)). “[W]hen a court is unable to render effective relief to a party, the case is deemed moot and usually dismissed.” C.J. v. State, 74 N.E.3d 572, 575 (Ind. Ct. App. 2017) (quoting J.M. v. Ne. Ctr., Inc. (In re J.M.), 62 N.E.3d 1208, 1210 (Ind. Ct. App. 2016)), trans. denied.

[7] At the hearing on November 21, 2024, the trial court placed D.C. in secure detention at the ACJC until December 3, 2024. D.C. challenges the trial court's decision to place him in the ACJC for fourteen days, but it is undisputed D.C. has since been released. Because D.C. only challenges the placement at ACJC, and his term of detention has since concluded, we cannot provide him with effective relief. Therefore, we dismiss this appeal as moot.

[8] Dismissed.

FOOTNOTES

1.   We note that Appellant failed to file a reply brief.

2.   Because this issue is dispositive, we do not address other issues.

Foley, Judge.

Kenworthy, J. and Scheele, J., concur.