B.R. Appellant-Respondent, v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] B.R. appeals the juvenile court's order committing him to the Indiana Department of Correction (the DOC). B.R. claims that the juvenile court abused its discretion by making him a ward of the DOC because less restrictive placement alternatives were more appropriate.

[2] We affirm.

Facts and Procedural History

[3] B.R., born on May 31, 2008, first entered the juvenile system at the age of twelve, following an adjudication for theft, a Class A misdemeanor, had that offense been committed by an adult. The juvenile court placed B.R. on probation for six months and ordered him to undergo therapy and participate in medication management. Shortly thereafter, the State alleged that B.R. committed resisting law enforcement, domestic battery, and intimidation, all Class A misdemeanors, had those offenses been committed by an adult. B.R. was again placed on probation.

[4] In June 2021, B.R. was adjudicated delinquent for leaving home without his parents’ permission,¹ and the juvenile court placed him on probation along with referrals for therapy, skills coaching, and medication management. Two days later, the State alleged that B.R. was delinquent for habitually disobeying a parent that resulted in the same informal probation.

[5] In September 2021, the State alleged that B.R. committed intimidation, a Level 6 felony, had the offense been committed by an adult. B.R. was placed on probation for one year and was ordered to undergo random drug testing, therapy, skills coaching, and medication management. The juvenile court also placed B.R. on sixty days of electronic home detention with a directive to refrain from possessing internet-capable electronic devices.

[6] On March 31, 2022, B.R. was alleged to have committed strangulation and intimidation, both Level 6 felonies, and domestic battery, a class A misdemeanor, had those offenses been committed by an adult. B.R. admitted the allegations and the juvenile court found B.R. delinquent, continued his probation, and imposed the same conditions as those in the 2021 intimidation adjudication.

[7] After review hearings in early 2022, the juvenile court ordered placement for B.R. at Transitions Academy (Transitions)—an organization that provides a secure, 24-hour residential treatment program and school for at-risk male adolescents. B.R. remained at Transitions until May 2023, after which he was released to probation with continued therapeutic services. B.R. was successfully discharged from probation in July 2023.

[8] In November 2023, the juvenile court adjudicated B.R. delinquent for committing theft, a Level 6 felony if committed by an adult, after he stole a moped from another individual. The juvenile court placed B.R. on six months of probation and ordered him to undergo random drug testing, therapy, medication management, and home-based services.

[9] In September 2024, the State alleged that B.R. possessed marijuana, although the prosecutor did not pursue the action. B.R. was then alleged to have left his home without his parents’ permission in June 2025. The prosecutor took no further action regarding that allegation.

[10] On June 6, 2025, the State alleged that B.R. committed battery resulting in bodily injury, a Class A misdemeanor, had that offense been committed by an adult. On August 4, 2025, the juvenile court ordered B.R. to remain on home detention and electronic monitoring, and ordered him to pass all drug tests, remain in good standing at his high school, participate in “Adulting 101,” and seek employment. Appellant's Appendix Vol. II at 71.

[11] B.R. received special education services during high school pursuant to an individualized education plan. That plan identified B.R. with emotional and intellectual disabilities. B.R. was also diagnosed by other medical professionals with post-traumatic stress disorder. At some point, it was learned that B.R. routinely associated with other at-risk individuals and wanted to join a gang.

[12] The present delinquency matter stemmed from events that occurred in August 2025. B.R. was alleged to have committed battery resulting in moderate bodily injury, a Level 6 felony, had the offense been committed by an adult. The victim claimed that B.R. and another individual pointed a firearm at him, took his phone, and punched him. During the pendency of those proceedings, B.R. submitted to a drug screen and tested positive for both THC and alcohol. At the time, B.R. was on court-ordered home detention with electronic monitoring. B.R. had friends visit him at home despite rules that prohibited visitors.

[13] B.R. ultimately admitted to the battery allegation and the juvenile court adjudicated him a delinquent child. At the dispositional hearing on December 15, 2025, the State informed the juvenile court that Transitions was the only residential placement facility that would accept B.R. The deputy prosecutor argued, however, that B.R. would not benefit from that placement because of his history of delinquency. Thus, the State requested the juvenile court to declare B.R. a ward of the DOC. The probation department agreed with the State's recommendation because of B.R.’s history and his previous failed opportunities at reform.

[14] Following the hearing, the juvenile court awarded wardship of B.R. to the DOC. That decision was based upon the numerous community-based and residential resources that had been exhausted, B.R.’s continued association with troubled youth, and B.R.’s habit of “leaving victims in his path of criminal activity.” Appellant's Appendix Vol. II at 24. The juvenile court concluded that commitment to the DOC was necessary for both community safety and B.R.’s welfare.

[15] B.R. now appeals.

Discussion and Decision

[16] A juvenile court generally enjoys “wide latitude and great flexibility” in juvenile matters, and its placement decisions are reviewed for an abuse of discretion. K.S. v. State, 114 N.E.3d 849, 854 (Ind. Ct. App. 2018), trans. denied. An abuse of discretion occurs when the trial court's decision is clearly against the logic and effect of the facts and circumstances before the court, or the decision reflects a misapplication of the law. J.Q.R. v. State, 252 N.E.3d 919, 924 (Ind. 2025).

[17] The juvenile court's discretion with placement decisions is regulated by statute. R.A. v. State, 936 N.E.2d 1289, 1291 (Ind. Ct. App. 2010). In placing a delinquent child, the juvenile court must exercise its discretion within the parameters of Ind. Code § 31-37-18-6. This statute provides, among other things, 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 ․ the least restrictive ․ and most appropriate setting available; ․ [and] imposes the least restraint on the freedom of the child․” Id.

[18] Although the statute requires the juvenile court to select the least restrictive placement that is appropriate, it is also recognized that in certain situations “the best interest of the child is better served by more restrictive placements.” M.M. v. State, 189 N.E.3d 1163, 1165 (Ind. Ct. App. 2022). And even if a less harsh option may exist at the time of a juvenile's disposition, commitment to a suitable public institution might still be in the best interest of the juvenile and of society. D.S. v. State, 829 N.E.2d 1081, 1085 (Ind. Ct. App. 2005). Placement in a DOC facility is not a punishment, but ensures that the juvenile “receives, in a secure environment, the extended rehabilitative counseling” that he needs. M.C. v. State, 134 N.E.3d 453, 461 (Ind. Ct. App. 2019), trans. denied.

[19] Here, B.R.’s involvement in the juvenile justice system began when he was twelve and his delinquency history is lengthy. B.R.’s adjudications include theft, resisting law enforcement, battery, intimidation, and strangulation, had those offenses been committed by an adult.

[20] To be sure, the juvenile court afforded B.R. numerous opportunities to reform without making him a ward of the DOC, in that B.R. has received the benefit of probation, counseling, medication management, family services, electronic home detention, and structured residential placement. Those measures proved ineffective, as B.R. was not deterred from engaging in further delinquent behavior that posed a threat to himself and the community.

[21] It was also established that B.R. associated with other at-risk juveniles who were involved in the justice system, and he wanted to participate in gang culture. Given B.R.’s clear disregard of the rules and his failure to reform with less restrictive options that were offered, we conclude that the juvenile court did not abuse its discretion in finding that the DOC was necessary to conform B.R.’s behavior to the law so he could receive the treatment and services he needed. See, e.g., M.C., 134 N.E.3d at 459 (holding that the juvenile court did not abuse its discretion by placing the child in the DOC when the child continued to use drugs, violate rules, and commit new offenses after the juvenile court's involvement).

[22] Judgment affirmed.

FOOTNOTES

1.   B.R. lived with his father and stepmother in Huntington.

Altice, Judge.

Brown, J. and DeBoer, J., concur.