Placement of juvenile in DOC stands after appeal

A teenager now under the wardship of the Indiana Department of Correction lost arguments Wednesday that the decision to declare him a ward of the DOC was an abuse of discretion.

After several unsuccessful attempts at placing juvenile M.C. in home-based treatments and residential placement services through Marion and Rush County probations and the Department of Child Services in both of counties, a juvenile court granted wardship to the Department of Corrections.

M.C. appealed, arguing the juvenile court in Rush County abused its discretion and that such a determination violated the Equal Protection Clause of the 14th Amendment to the U.S. Constitution and the Equal Privileges and Immunities Clause of the Indiana Constitution. He also asserted the decision violated the cruel and unusual punishment provision of the Eighth Amendment to the U.S. Constitution and the proportionality clause of the Indiana Constitution.

The appellate court rejected his appeal, finding the evidence of his continued illegal substance use and failed rehabilitation attempts were “compelling reasons for a more closely-supervised and restrictive environment than a setting that would permit M.C. to reoffend and disregard the juvenile court’s rules.”

“Put another way, M.C.’s wardship to the DOC serves the juvenile justice system’s purpose, inasmuch as intervention was needed to prevent M.C.’s behavior from declining, with the hope that M.C. will not commit criminal offenses as an adult,” Judge Robert Altice wrote for the panel.

On his constitutional claims, the appellate court found the juvenile court’s treatment was well suited to provide structured guidance and personalized rehabilitative services to M.C. As a result, it concluded, the separate systems for juvenile delinquents and adult criminal offenders are rationally related to the goal of ensuring rehabilitation of juveniles. The appellate court likewise denied M.C.’s assertion that he was denied the privileges and immunities guaranteed under the Indiana Constitution, Article 1, Section 23 of the Indiana Constitution.

Lastly, it found M.C.’s claims that awarding wardship to the DOC was cruel and unusual punishment and violated the proportionality provision of Article 1, Section 16 of the Indiana Constitution, to be unavailing. The appellate court concluded that juvenile proceedings are not criminal in nature and do not amount to a direct action by the state to inflict punishment upon a juvenile.

The trial court’s judgment was thus affirmed in M C v. State of Indiana, 19A-JV-00703.

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