A.M., Appellant-Respondent v. STATE (2026)

MEMORANDUM DECISION

[1] Following a police search of a vehicle in which sixteen-year-old A.M. was a passenger, the State filed a delinquency petition alleging she committed dangerous possession of a firearm and possession of marijuana. At a later factfinding hearing, A.M. agreed to admit to the charges and made admissions to establish a factual basis. The juvenile court accepted her admissions, found her to be a delinquent child, and ordered her to serve a sentence on probation with electronic monitoring. A.M. now appeals, challenging whether her factual admissions were sufficient to establish the offenses charged and whether her placement on electronic monitoring was appropriate.

[2] The State argues this appeal should be dismissed without prejudice, and we agree. In J.W. v. State, 113 N.E.3d 1202, 1208 (Ind. 2019), our Supreme Court announced a “bright-lined rule” for juveniles like A.M. who are “challenging the legality of an adjudication agreement.” The court held,

A juvenile's claim that [her] agreed delinquency adjudication is unlawful, along with any claim premised on the agreement's illegality, cannot be raised on direct appeal. Such claims must first be brought in the juvenile court in a post-judgment motion under [Indiana Trial] Rule 60.

Id. at 1208. Because A.M. has not previously presented these claims to the juvenile court under a Rule 60 motion, her direct appeal is “premature.” Id. Nor can we address A.M.’s claim as to her placement on electronic monitoring, given the rule in J.W. calls for dismissal of the “entire appeal” notwithstanding the presence of additional claims that may be “ripe for appellate disposition.” Id. We therefore dismiss her appeal without prejudice so she may pursue a motion for relief from judgment in the trial court.

[3] Dismissed.

Scheele, Judge.

Brown, J., and Felix, J., concur.