J.L., Appellant-Respondent v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] J.L., while on probation for what would be auto theft and battery if committed by an adult, was found to be a delinquent child for committing what, if committed by an adult, would be two counts of Class A misdemeanor criminal mischief and Class A misdemeanor criminal trespass. After J.L. admitted to having committed the delinquent acts, the juvenile court ordered that J.L. be committed to the Indiana Department of Correction (“DOC”). J.L. contends that the juvenile court abused its discretion in doing so, arguing that less-restrictive placement options were available. We affirm.

Facts and Procedural History

[2] In the spring of 2025, Richard Monroe owned property in Jay County (“the Property”). The Property was unoccupied, but Monroe and his daughter stored personal items in a home and a barn located there. Monroe's daughter also stored a camper on the Property. Monroe had posted “[n]o trespassing” signs around the Property. Appellant's App. Vol. II p. 9.

[3] Sometime in April of 2025, J.L., whose date of birth was November 25, 2009, and a friend, J.S., entered the Property without permission. While on the Property, J.L. pried open the rear window of the camper, which had been locked, breaking the latch. J.L. entered the camper through the window, damaging the blinds. J.L. “ransacked” the camper, breaking at least one drawer and ruining some bedding. Appellant's App. Vol. II p. 9.

[4] J.L. and J.S. unsuccessfully attempted to enter the home, which also had been locked, through the back door, causing significant damage to the door by “using a prying tool to” try to gain entry, tearing out a screen, and damaging the locking mechanism. Appellant's App. Vol. II p. 9. Eventually, J.L. and J.S. gained access to the home through a basement window. Once inside the home, someone urinated and defecated in the toilet. J.L. and J.S. left cigarette butts, a gaming system, and several water bottles lying around the home. They hung a sign in the living room that read, “The Doobie Den lets Get High.” Appellant's App. Vol. II p. 10. J.S. later admitted that he and J.L. had used the home “as a hangout[,]” and had entered the home “many times in the last couple weeks leading up to when” Monroe discovered the damage. Appellant's App. Vol. II p. 10. J.L. and J.S. also entered the locked barn but did not cause any damage in the barn.

[5] On June 3, 2025, the State filed a delinquency petition alleging that J.L. was a delinquent child for committing what, if committed by an adult, would be two counts of Class A misdemeanor criminal mischief and Class A misdemeanor criminal trespass. On August 7, 2025, J.L. admitted to the allegations in the petition.

[6] At the time he committed the instant delinquent acts, J.L. was on probation for acts that would constitute auto theft and battery if committed by an adult. During a dispositional hearing, J.L.’s probation officer testified that he “has struggled with following rules throughout the duration of being on probation. He has violated multiple rules․ He was not participating actively in his mental health services and he was not participating in his educational services either.” Tr. Vol. II p. 27. J.L.’s probation officer further indicated that J.L. had also admitted to—and tested positive for—illegal drug use.

[7] On September 16, 2025, the juvenile court awarded “wardship of [J.L.] to the [DOC] for housing at an appropriate juvenile facility.” Appellant's App. Vol. II p. 32 (emphasis omitted). In ordering that J.L. be committed to the DOC, the juvenile court found that

1. This is [J.L.’s] second adjudication.

2. [J.L.] has repeatedly violated the rules of probation.

3. [J.L.] was on probation in an unrelated cause when he committed this offense.

4. Despite less restrictive dispositions, [J.L.] continues to violate the law.

Appellant's App. Vol. II p. 32. The juvenile court further found that “continuation in the home is not in [J.L.]’s best interest and that reasonable efforts have been made to prevent placement.” Appellant's App. Vol. II p. 32

Discussion and Decision

[8] J.L. contends that the juvenile court abused its discretion in committing him to the DOC because other, less-restrictive, options were available.

The juvenile court has wide latitude and great flexibility in its dealings with juveniles. J.S. v. State, 881 N.E.2d 26, 28 (Ind. Ct. App. 2008). The choice of the specific disposition of a juvenile adjudicated a delinquent child is a matter within the sound discretion of the juvenile court and will be reversed only if there has been an abuse of that discretion. Id. The juvenile court's discretion is 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. Id. An abuse of discretion occurs when the juvenile court's action is clearly erroneous and against the logic and effect of the facts and circumstances before the court or the reasonable, probable, and actual inferences that can be drawn therefrom. Id.

In re M.T., 928 N.E.2d 266, 268 (Ind. Ct. App. 2010), trans. denied.

[9] Indiana Code section 31-37-18-6 provides that

[i]f 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.

[10] In arguing that the juvenile court abused its discretion in ordering that he be committed to the DOC, J.L. asserts that the juvenile court “had less restrictive options available that were still consistent with the safety of the community and [his] best interests” and “had options available which would be less disruptive to family life[.]” Appellant's Br. p. 10. Specifically, J.L. asserts that “[e]ither a commitment to secure detention or a period of electronically monitored home detention would have been less restrictive, more family-like, less disruptive and would have permitted more parental participation.” Appellant's Br. p. 11.

[11] J.L. fails to acknowledge, however, that less-restrictive placements and prior efforts to rehabilitate him had been unsuccessful. J.L. was on probation for prior delinquent acts that, if committed by an adult, would have been auto theft and battery at the time he committed the instant delinquent acts. J.L. had committed numerous violations of his probation. J.L. had admitted to having used marijuana and had been suspended from school for possessing the drug. J.L. had “had police contact that ha[d] been referred to” the prosecutor's office and had also failed to actively participate in his mental-health and educational services. Tr. Vol. II p. 22. J.L. was also determined to be a moderate risk to reoffend.

[12] “In some instances, confinement may be one of the most effective rehabilitative techniques available[.]” K.A. v. State, 775 N.E.2d 382, 387 (Ind. Ct. App. 2002) (quoting Madaras v. State, 425 N.E.2d 670, 672 (Ind. Ct. App. 1981)), trans. denied. We conclude that this is one of those instances given that J.L. had continued to engage in delinquent conduct despite the juvenile court's prior, less-restrictive, attempts at rehabilitation. The juvenile court considered J.L.’s history, including the fact that prior attempts at rehabilitation had failed, before ordering that he be committed to the DOC. We cannot say that the juvenile court abused its discretion in this regard.

[13] The judgment of the juvenile court is affirmed.

Bradford, Judge.

Weissmann, J., and DeBoer, J., concur.