N.C., Appellant-Respondent v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] In September of 2025, after N.C. left his mother's home without permission, causing her to call the police, he was found to be a juvenile delinquent for having committed the juvenile offense of leaving home without permission. N.C. contends that the State produced insufficient evidence to support the juvenile court's finding that he had left his mother's home without reasonable cause. Because we disagree, we affirm.

Facts and Procedural History

[2] On September 25, 2025, N.C. left his mother's Marion home without her permission, returning later that evening. According to N.C.’s mother, he had run away, having left her house without permission, so she had called the police. On September 26, 2025, the State filed petitions in which it alleged that N.C. was a delinquent child for having committed the juvenile status offense of leaving home without permission and, stemming from events in May of 2025, what would be Class A misdemeanor domestic battery if committed by an adult; the juvenile court joined both petitions under cause number 27D02-2509-JD-106. On October 20, 2025, the juvenile court held a fact-finding hearing, after which it found that N.C. had committed the offense of leaving home without permission but not domestic battery. On December 15, 2025, the juvenile court ordered that N.C. be placed on formal probation for six months and participate in counseling.

Discussion and Decision

[3] When reviewing claims of insufficient evidence in a juvenile case, appellate courts apply the same standard of review as if it were an appeal of a criminal conviction. K.W. v. State, 984 N.E.2d 610, 612 (Ind. 2013). In reviewing a challenge to the sufficiency of the evidence, we do not reweigh the evidence or assess the credibility of witnesses. McHenry v. State, 820 N.E.2d 124, 126 (Ind. 2005). “It is the fact-finder's role, not that of appellate courts, to assess witness credibility and weigh the evidence to determine whether it is sufficient to support a conviction.” Drane v. State, 867 N.E.2d 144, 146 (Ind. 2007). We look only to evidence in a light most favorable to the juvenile court's ruling and must affirm the conviction unless no reasonable fact-finder could find the elements proven beyond a reasonable doubt. McHenry, 820 N.E.2d at 126. The evidence need not overcome every reasonable hypothesis of innocence. Craig v. State, 730 N.E.2d 1262, 1266 (Ind. 2000).

[4] Indiana Code section 31-37-2-2 provides that “[a] child commits a delinquent act if, before becoming eighteen (18) years of age, the child leaves home or a specific location previously designated by the child's parent [․]: (1) without reasonable cause; and (2) without permission of the parent [․] who requests the child's return.” Because N.C. was adjudicated delinquent for a status offense (i.e., an act that would not be a crime if committed by an adult), his adjudication is subject to the two-pronged inquiry under Indiana Code section 31-37-2-1. R.B. v. State, 839 N.E.2d 1282, 1284 (Ind. Ct. App. 2005). To support a true finding, then, there must be sufficient evidence for the juvenile court to determine that N.C. committed the act of leaving without permission and he needed care, treatment, or rehabilitation. Id.

[5] Here, N.C. challenges only the finding that he had left home without reasonable cause. N.C. testified at the hearing that he had left home because his mother had been “drunk and high off methamphetamine, and she just kept non stop yelling and trying to create problems[.]” Tr. Vol. II p. 28. According to N.C., he had gone on a walk around the block to “clear stuff up” and see if his mother “would be calmed down by the time [he] got back to the house.” Tr. Vol. II p. 28. The juvenile court, however, was under no obligation to credit this testimony, which, as N.C. concedes, is the only evidence tending to show that he had had reasonable cause for leaving home without permission. In the end, N.C.’s challenge amounts to nothing more than a request to reweigh the evidence, which we will not do. See, e.g., B.T.E. v. State, 108 N.E.3d 322, 326 (Ind. 2018).

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

Bradford, Judge.

Tavitas, C.J., and Felix, J., concur.