STATE IN INTEREST OF v. << (2026)

This matter arises out of a juvenile disposition. Appellant, State of Louisiana, filed an appeal seeking review of the juvenile court's judgment which ordered a deferred disposition of Appellee, N.T.¹ , pursuant to La. Ch.C. art. 896. For the reasons that follow, the State's appeal is dismissed as moot.

FACTUAL AND PROCEDURAL HISTORY

On September 18, 2025, N.T. admitted to five counts of theft of a motor vehicle (La. R.S. 14:67.26); one count of attempted theft of a motor vehicle (La. R.S. 14:(27)67.26); and two counts of simple burglary (La. R.S. 14:62). Based on the admissions, the juvenile court adjudicated N.T. as delinquent. The juvenile court initially ordered a disposition of sixteen months and one week of probation. However, the court reconsidered the disposition and entered a deferred disposition. The deferred disposition referred N.T. to actively participate in the court's Teen Program; ordered N.T. to report to his assigned Teen Court manager; and released N.T. into the custody and control of his mother.

In response to the deferred disposition, the State filed a Motion to Correct Illegal Deferred Disposition. At the hearing on the motion, the State relied on La. Ch.C. art. 896(H), which provides that “[n]otwithstanding any provision of law to the contrary, a child shall not be eligible for a deferred dispositional agreement as provided in this Article if the child has been convicted of a crime of violence as defined in R.S. 14.2(B). Therefore, the State claimed N.T.’s deferred disposition was illegal because N.T. had previously been adjudicated for two crimes of violence. The juvenile court denied the State's motion and the State filed the present appeal.

The State's appeal was lodged with this Court on December 5, 2025. On February 2, 2026, the State filed a motion to dismiss its appeal as moot.

DISCUSSION

In support of the motion to dismiss, the State attached a January 27, 2026 written disposition from the juvenile court which revoked N.T.’s September 18, 2025 deferred disposition. The disposition ordered the following:

IT IS ORDERED, ADJUDGED, AND DECREED that: Based on the juvenile's new arrest on December 9, 2026, under Art. 896 Disposition, the Court finds that said disposition is hereby DISMISSED.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that: the juvenile [N.T.], will be sentenced for a period of SIX (6) MONTHS DETENTION on all charges listed in the petition and is to receive credit-for-time served noting that the juvenile has already served the time of six (6) months.

As expounded in Ass'n of Cemetery Tour Guides & Companies L3C v. New Orleans Archdiocesan Cemeteries, 2024-0044, p. 18 (La. App 4 Cir. 9/4/24), 401 So.3d 797, 808, “[t]he jurisprudence of this Court is well settled that courts will not decide abstract, hypothetical or moot controversies, or render advisory opinions with respect to such controversies,” quoting Cat's Meow, Inc. v. City of New Orleans Through Dep't of Fin., 98-0601, p. 8 (La. 10/20/98), 720 So. 2d 1186, 1193. Here, the juvenile court's dismissal of the deferred disposition sentence renders the controversy on appeal—the legality of the disposition—as moot. Accordingly, this Court must dismiss the appeal.

DECREE

Based on the foregoing reasons, we grant the State's motion to dismiss and the appeal of this matter is hereby dismissed as moot.

APPEAL DISMISSED

FOOTNOTES

1.   To maintain the confidentiality of the juvenile court proceedings as required by La. Ch.C. articles 407 and 412, we shall reference the juvenile herein by his initials.

Judge Sandra Cabrina Jenkins