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

MEMORANDUM DECISION

Statement of the Case

[1] While on probation for a previous juvenile adjudication, D.L. violated the terms of his probation by breaking curfew, drinking alcoholic beverages, disobeying directions from his mother, and testing positive for THC. Following a modification hearing, the juvenile court ordered D.L. to be placed at the Indiana Department of Correction (“DOC”). D.L. now appeals, raising one issue for our review: Whether the juvenile court abused its discretion by awarding wardship of D.L. to the DOC.

[2] We affirm.

Facts and Procedural History

[3] In February 2025, D.L., a minor who had been adjudicated delinquent and was on probation for criminal mischief, was again adjudicated a delinquent after admitting he possessed marijuana, which would be a Class A misdemeanor if committed by an adult. The juvenile court ordered D.L. be detained pending disposition at the Dearborn County Juvenile Center, for the protection of D.L. and the community based on his history of aggression, marijuana use, and leaving home without permission. After the dispositional hearing, the juvenile court released D.L. to his mother's care and placed him on six months of reporting probation.

[4] In July, the State filed a petition to modify D.L.’s disposition, alleging that D.L. violated the terms of his probation by returning home after curfew, visiting a friend's residence without his mother's permission, drinking alcohol, and testing positive for THC. During an initial hearing on the modification, a probation officer testified that D.L. was yelling and “cussing” at his mother and sister and on one occasion, “yelled, ‘let me hit the b[*]tch,’ ” referring to his sister. Tr. Vol. II at 49. Upon the recommendation of the probation officer and with the support of the State and D.L.’s mother, the juvenile court ordered D.L. be detained because he continued to use marijuana and be aggressive toward his family.

[5] During the modification hearing, D.L. admitted to the violations. At the dispositional hearing, a probation officer testified that D.L.’s prior juvenile history included an informal adjustment for battery and a delinquency adjudication for criminal mischief. Additionally, D.L. had a history of violating probation and refusing to follow his mother's rules. According to the probation officer, D.L. “uses intimidation to try to get his way[,] and when he doesn't get his way, he is belligerent.” Tr. Vol. II at 71. The probation officer further testified that D.L.’s “aggressive misbehavior continues,” particularly toward his mother, “[d]espite the plethora of services that have been provided.” Id. For instance, the probation department received reports of D.L. “slamming doors, screaming and yelling,” id., resulting in law enforcement being called.

[6] After the dispositional hearing, the juvenile court awarded wardship of D.L. to the DOC, finding that D.L.’s history of delinquent behavior was “atrocious” and showed a “complete disregard at times for the law” and his “mother's authority.” Tr. Vol. II at 86. In its written order, the juvenile court found that D.L. was dangerous to himself and others, community resources were exhausted, and he had a “history of delinquent activity and violating court[-]ordered conditions,” Appellant's App. Vol. II at 131. D.L. now appeals.

Discussion and Decision

The Juvenile Court Did Not Abuse Its Discretion by Awarding Wardship of D.L. to the DOC

[7] D.L. challenges the juvenile court's decision to award wardship of him to the DOC. “Juvenile courts enjoy wide latitude and significant flexibility in their dealings with juveniles.” B.K. v. State, 235 N.E.3d 142, 145 (Ind. 2024) (citing In re M.T., 928 N.E.2d 266, 268 (Ind. Ct. App. 2010)). The disposition of a delinquent is guided by the following relevant statutory considerations: the safety of the community; the best interests of the juvenile; the least restrictive alternative; family autonomy and life; freedom of the juvenile; and the freedom and participation of the juvenile's parent, guardian, or custodian. Ind. Code § 31-37-18-6.

[8] We review a juvenile court's disposition decision for an abuse of discretion. G.W. v. State, 231 N.E.3d 184, 188 (Ind. 2024) (citing K.S. v. State, 114 N.E.3d 849, 854 (Ind. Ct. App. 2018)). “A court abuses its discretion by misinterpreting the law or ‘if its decision clearly contravenes the logic and effect of the facts and circumstances before it.’ ” Id. (quoting T.D. v. State, 219 N.E.3d 719, 724 (Ind. 2023)). “In determining whether a juvenile court has abused its discretion, we neither reweigh the evidence nor judge witness credibility.” A.F. v. State, 247 N.E.3d 841, 843 (Ind. Ct. App. 2024) (citing Q.H. v. State, 216 N.E.3d 1197, 1200 (Ind. Ct. App. 2023)).

[9] Initially, we note that “commitment to the DOC ‘should be treated as a last resort,’ ” G.W., 231 N.E.3d at 190 (quoting C.H. v. State, 201 N.E.3d 202, 205 (Ind. Ct. App. 2022)), but “that option may be appropriate when ‘consistent with the safety of the community and the best interest of the child,’ ” id. (quoting I.C. § 31-37-18-6). As this court has previously observed, placement with the DOC is not a penalty—the DOC is a secure environment that can better serve the overall purpose of rehabilitating a juvenile. M.C. v. State, 134 N.E.3d 453, 461 (Ind. Ct. App. 2019) (quoting S.C. v. State, 779 N.E.2d 937, 940 (Ind. Ct. App. 2002), trans. denied), trans. denied, cert. denied.

[10] D.L. specifically argues that the juvenile court abused its discretion by committing him to the DOC because his violations were nonviolent and there were “less restrictive options available.” Appellant's Br. at 13. D.L.’s argument ignores the numerous chances the juvenile court gave him to improve his behavior through less restrictive options. Each time he was placed on probation and returned to his mother's care, D.L. failed to comply with the conditions of his probation by committing new violations. D.L. was given opportunities to participate in casework, counseling services, and rehabilitative services through the Youth Encouragement Services Home but continued to engage in delinquent behavior. The juvenile court found that “community resources ha[d] been exhausted that c[ould] adequately address the safety concerns for both [D.L.] and the community.” Tr. Vol. II at 89.

[11] Additionally, D.L. exhibited a concerning pattern of aggressive behavior. In 2023, D.L. was placed on informal adjustment for battery. The following year, D.L.’s second encounter with the juvenile court system involved an alleged domestic violence incident. Despite treatment, D.L. continued to behave aggressively toward his mother and sister during stressful situations. For instance, in August 2025, law enforcement responded to D.L.’s home because D.L. was “screaming, cussing, and throwing things.” Tr. Vol. II at 49. On another occasion, D.L. was upset with his sister and yelled, “[L]et me hit the b[*]tch.” Id.

[12] D.L. nevertheless claims his need for mental health treatment should have led the juvenile court to place him in a qualified residential treatment facility instead of the DOC. This claim is merely a request for us to reweigh the evidence and reassess witness credibility, which we cannot do. See A.F., 247 N.E.3d at 843 (citing Q.H., 216 N.E.3d at 1200). The juvenile court was in the best position to evaluate whether the DOC was an appropriate placement given D.L.’s need for treatment, continued violations, and violent outbursts.

[13] The record here clearly demonstrates that D.L.’s placement at the DOC is consistent with the safety of the community and D.L.’s best interests, so we cannot say the juvenile court abused its discretion by awarding wardship of D.L. to the DOC. We therefore affirm the juvenile court.

[14] Affirmed.

Felix, Judge.

Tavitas, C.J., and Bradford, J., concur.