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

MEMORANDUM DECISION

[1] R.M. appeals the juvenile court's grant of wardship over her to the Indiana Department of Correction (“DOC”). R.M. raises a single issue for our review, namely, whether the juvenile court abused its discretion when it placed her in the care of the DOC. We affirm.

Facts and Procedural History

[2] In 2024, R.M. struck an adult at her school in the face with a closed fist and threatened to shoot a classmate and others. Following her arrest, a juvenile court adjudicated R.M. to be a delinquent for acts of intimidation, as a Level 6 felony if committed by an adult, and battery, as a Class B misdemeanor if committed by an adult.

[3] The juvenile court placed R.M. on probation. However, in 2025, R.M. violated the conditions of her probation when she left home without authorization. Later in 2025, R.M. again violated the conditions of her probation due to misbehavior at her school and truancy.

[4] In January 2026, R.M., now a freshman in high school, hit her mother in the chest and arms during a physical altercation in their home. R.M.’s mother called police and informed officers that R.M. could not remain in the home. R.M. refused to participate in a residential placement.

[5] The State alleged R.M. to be a delinquent child for having committed an act of disorderly conduct, a Class B misdemeanor if committed by an adult, when R.M. struck her mother. R.M. admitted to the allegation. At the ensuing dispositional hearing, a probation officer informed the court that “community-based services” for R.M. “have been exhausted” due in part to her “history of aggression ․” Tr. Vol. 2, p. 33. The officer further stated that mental-health professionals on staff believed that “commitment to the Department of Correction would be most appropriate ․ at this point in time to try to help [R.M.] overcome her pattern of aggression and threatening behavior.” Id.

[6] The trial court adopted the probation department's recommendation and ordered wardship over R.M. to be granted to the DOC. This appeal ensued.

Discussion and Decision

[7] On appeal, R.M. asserts that the juvenile court abused its discretion when it granted wardship over her to the DOC. The “juvenile court is accorded wide latitude and great flexibility in its dealings with juveniles.” M.C. v. State, 134 N.E.3d 453, 458 (Ind. Ct. App. 2019), trans. denied. Thus, we will reverse the court's choice of the specific disposition of a juvenile adjudicated a delinquent child only for an abuse of discretion. Id. The “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. The trial court abuses its discretion only when its decision is “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.

[8] The choice of an appropriate juvenile disposition is governed by Indiana Code section 31-37-18-6 (2025), which provides as follows:

If 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.

Thus, “placement in the least restrictive setting is required only ‘[i]f consistent with the safety of the community and the best interest of the child.’ ” R.H. v. State, 937 N.E.2d 386, 391 (Ind. Ct. App. 2010) (quoting I.C. § 31-37-18-6). In so stating, “the statute recognizes that in certain situations the best interest of the child is better served by a more restrictive placement.” J.S. v. State, 881 N.E.2d 26, 29 (Ind. Ct. App. 2008).

[9] The juvenile court's decision to place R.M. in the care of the DOC is supported by the facts and circumstances before the court. R.M. admitted to having struck her mother in the family home, and her admission was consistent with a long pattern of aggressive behavior toward others. R.M. violated prior less-restrictive placements on multiple occasions. She refused to participate in residential placements. And mental-health experts within the probation department concluded that R.M.’s placement in the DOC would be in her best interests.

[10] R.M. argues on appeal that her mother was willing to bring R.M. back into the family home. But R.M.’s position is ambiguous; immediately after the disorderly conduct, R.M.’s mother said R.M. could not return to the family home. Only later did R.M.’s mother say otherwise. R.M.’s argument on appeal simply asks our Court to reweigh the evidence and to substitute our judgment for that of the juvenile court, which we will not do.

[11] The juvenile court's grant of wardship over R.M. to the DOC is affirmed.

[12] Affirmed.

Mathias, Judge.

Pyle, J., and Weissmann, J., concur.