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

MEMORANDUM DECISION

Case Summary

[1] In September of 2025, the State alleged that the then-fifteen-year-old L.M. had committed what would be Level 6 felony institutional mischief and Class B misdemeanor battery, if committed by an adult. After L.M. admitted the allegations against him, the juvenile court ordered that he be committed to the Indiana Department of Correction (“DOC”). L.M. contends that the juvenile court abused its discretion in committing him to the DOC. Because we disagree, we affirm.

Facts and Procedural History

[2] On August 26, 2025, Lebanon Police were dispatched to the Indiana United Methodist Children's Home (“IUMCH”) to investigate a fight involving two residents, L.M. and L.P. Police learned that L.M. and L.P. had been playing basketball when L.M. had pushed L.P. and punched him with a closed fist. At some point, L.M. had also punched a glass entrance door and the concrete wall next to it, causing more than $750.00 in damage to the door. On September 4, 2025, the State alleged that L.M. was a juvenile delinquent for committing what would be Level 6 felony institutional mischief and Class B misdemeanor battery, if committed by an adult. On September 11, 2025, L.M. admitted the allegations in the delinquency petition.

[3] On September 25, 2025, the juvenile court held a dispositional hearing. Jeremy Haven, L.M.’s probation officer, testified that L.M. had had several placements since late 2023, including Henry County Juvenile Probation, Paddock View, DAMAR for diagnostic, White's Residential, other residential placements in Delaware and Hamilton County, and finally IUMCH. Haven indicated that IUMCH had requested that L.M. be removed, citing a pattern of behaviors including

going awol, leaving the campus without permission, they reported at least five (5) to six (6) days of that happening. They reported [L.M.] having inappropriate behaviors with some of the other residents that were there. There was also significant damage to property and there's been multiple reports of [L.M.] being in possession of contraband, electronics’, [(sic)] things that he is not supposed to have access to or have possession of.

Tr. Vol. II p. 11. Because all of L.M.’s previous placements had reported the “same pattern of behavior,” Haven recommended placement in the DOC Indiana Boy's School, agreeing that it was the “least restrictive placement that will keep him and the community safe[.]” Tr. Vol. II p. 11. The juvenile court, indicating that it did not “know that there are any other things we haven't tried yet[,]” ordered L.M. committed to the DOC as “the only option we have left.” Tr. Vol. II pp. 13, 14.

Discussion and Decision

[4] L.M. contends that the juvenile court abused its discretion in ordering him committed to the DOC. The disposition of a juvenile delinquent is committed to the juvenile court's sound discretion, “subject to the statutory considerations of the welfare of the child, the community's safety, and the Indiana Code's policy of favoring the least harsh disposition.” E.H. v. State, 764 N.E.2d 681, 684 (Ind. Ct. App. 2002), trans. denied. A juvenile court's disposition will not be reversed absent a showing of an abuse of discretion, which occurs only if its action is “clearly erroneous and against the logic and effect of the facts and circumstances before the court, or the reasonable, probable, and actual deductions to be drawn therefrom.” Id. “In reviewing a juvenile adjudication, this court will consider only the evidence and reasonable inferences supporting the judgment and will neither reweigh evidence nor judge the credibility of the witnesses.” J.L. v. State, 5 N.E.3d 431, 442 (Ind. Ct. App. 2014).

[5] “Although the juvenile court is given wide latitude and great flexibility in determining the disposition of a delinquent child, its discretion is circumscribed by statute.” R.A. v. State, 936 N.E.2d 1289, 1291 (Ind. Ct. App. 2010). Indiana Code section 31-37-18-6 provides, in part, 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 [․] is [․] in the least restrictive [․] and most appropriate setting available[.]” Although the statute requires the least-restrictive placement when appropriate, it recognizes that, at times, the best interests of the child are better served by a more-restrictive placement. K.A. v. State, 775 N.E.2d 382, 386–87 (Ind. Ct. App. 2002), trans. denied.

[6] We have little trouble concluding that the juvenile court acted within its discretion in ordering L.M. committed to the DOC. For one thing, other, less-restrictive means of rehabilitation had repeatedly been attempted without success, including Henry County juvenile probation, Paddock View, DAMAR for diagnostic services, White's Residential, other placements in Delaware and Hamilton Counties, and finally IUMCH. L.M. was in IUMCH, a less-restrictive placement, when he committed the delinquent acts in this case, and IUMCH requested his removal. The juvenile court also heard Haven's recommendation that L.M. be committed to the DOC, where he would have access to “medical services, vocational services, counseling, and educational” and his opinion that “it is in [L.M.’s] best interest to be safe and give him his best chance of eventually returning home and not getting in trouble again.” Tr. Vol. II p. 11. In summary, the juvenile court heard evidence regarding the failures of L.M.’s less-restrictive placements over the course of two years that DOC placement was in his best interests. This evidence is sufficient to support the juvenile court's adjudication. See, e.g., J.S. v. State, 881 N.E.2d 26, 29 (Ind. Ct. App. 2008) (“[I]t is well settled that there are times when commitment to a suitable public institution is in the best interest of the juvenile and society.”) (citation, quotation marks, and emphasis omitted).

[7] L.M. argues that the juvenile court abused its discretion in ordering him committed to the DOC because his behavioral problems “likely stem from untreated or inadequately treated mental health issues, not from criminal tendencies” and “the juvenile court made no findings about why a therapeutic mental health placement was insufficient or unavailable.” Appellant's Br. p. 10. L.M. also points to DAMAR's prior determination that residential placement was the most appropriate placement for him. The record, however, does not reveal when DAMAR's evaluation took place, and, in any event, does reveal the failures of one residential placement after another. Moreover, Haven specifically recommended DOC placement, in part, on the basis that L.M. would have access to “medical treatment,” Appellant's App. Vol. II p. 46, and “medical services[.]” Tr. Vol. II p. 11. In the end, L.M.’s argument is nothing more than an invitation to reweigh the evidence, which we will not do. See, e.g., J.L., 5 N.E.3d at 442.

[8] We affirm the judgment of the juvenile court.

Bradford, Judge.

Pyle, J., and Kenworthy, J., concur.