Rush, C.J.
Indiana has long been a pioneer in safeguarding a juvenile offender’s constitutional rights. See, e.g., Frank Sullivan, Jr., Indiana as a Forerunner in the Juvenile Court Movement, 30 Ind. L. Rev. 279 (1997); Frank Sullivan, Jr., Selected Developments in Indiana Juvenile Justice Law (1993–2012), 48 Ind. L. Rev. 1541, 1547–56 (2015). In 1903, our state became one of the first in the nation to establish juvenile courts and the first to guarantee the right to a jury trial to children. Decades later, the U.S. Supreme Court issued a series of decisions guaranteeing constitutional rights to children in juvenile proceedings. This Court, however, provided even greater protections by requiring courts to advise children of their rights at each stage of the juvenile proceedings along with the opportunity to consult with their attorney, parent, or guardian before waiving those rights. Shortly thereafter, the Legislature adopted these heightened protections in our first juvenile-waiver statute. Today, this statute continues to provide the procedural framework trial courts must comply with before accepting a juvenile’s waiver.
Here, both parties agree the trial court failed to comply with the juvenile-waiver statute before accepting a juvenile’s delinquency admission, but they disagree on the effect of that error. We first hold that the court’s error did not render the judgment void, and thus, the juvenile is not entitled to relief under Trial Rule 60(B)(6). But we then hold that the juvenile is entitled to relief under Trial Rule 60(B)(8). He demonstrated that the court failed to comply with the juvenile-waiver statute before accepting his admission, and the State did not present any evidence establishing that his waiver was nevertheless valid under the statute. As a result, we reverse.
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When children admit to delinquency allegations in lieu of proceeding to fact-finding, they give up several constitutional and statutory rights associated with trial. Though the same is true for adults who plead guilty, “admissions and confessions by juveniles require special caution.” Wehner v. State, 684 N.E.2d 539, 541 (Ind. Ct. App. 1997). And so, to ensure a child knowingly and voluntarily waives their rights before entering an admission, our Legislature has codified safeguards that require strict compliance. Hickman v. State, 654 N.E.2d 278, 281 (Ind. Ct. App. 1995).
The Legislature first codified these safeguards in 1978 when it enacted a new juvenile code with an express purpose of providing “a judicial procedure that ensures fair hearings and recognizes and enforces the constitutional and other legal rights of children and their parents.” Pub. L. No. 136, § 1, 1978 Ind. Acts 1196, 1197. To that end, the juvenile code established a framework that provided two ways for children to waive the rights conferred on them through state or federal law; both required adult participation, and both required the child to “knowingly and voluntarily join[] with the waiver on the record.” Id. at 1232. Despite a few amendments to the statute since, its overarching limitations and requirements remain in force today.
Indeed, the statute explains that the rights conferred on children through state or federal law can be waived in only three ways: (1) by counsel if the juvenile knowingly and voluntarily joins the waiver; (2) by the juvenile’s custodial parent, guardian, custodian, or guardian ad litem if that individual knowingly and voluntarily waives the rights, they have no adverse interests to the juvenile, they engaged in meaningful consultation with the juvenile, and the juvenile knowingly and voluntarily joins the waiver; or (3) by the juvenile if they are emancipated and knowingly and voluntarily consent to the waiver. Ind. Code § 31-32-5-1 (“Juvenile Waiver Statute”). By permitting a court to find waiver in only these limited circumstances, “the statute affords juveniles with greater rights than the Constitution requires.” R.R. v. State, 106 N.E.3d 1037, 1043 (Ind. 2018). Accordingly, our trial courts must take particular care to ensure a valid waiver of rights before accepting a juvenile’s admission. See Bryant v. State, 802 N.E.2d 486, 493 (Ind. Ct. App. 2004), trans. denied.
When, as here, the court fails to confirm or secure a waiver as required by the Juvenile Waiver Statute, Trial Rule 60(B) is the appropriate avenue for a juvenile to challenge their agreed delinquency adjudication. J.W. v. State, 113 N.E.3d 1202, 1207–08 (Ind. 2019). And, under this rule, the burden is on the juvenile to establish grounds for relief. G.B. v. State, 715 N.E.2d 951, 953 (Ind. Ct. App. 1999). T.D. sought relief under Rules 60(B)(6) and 60(B)(8). While the former permits relief when a court’s “judgment is void,” Ind. Trial Rule 60(B)(6), the latter permits relief for “any reason” other than those set forth in other subsections that are not relevant here, T.R. 60(B)(8). Additionally, Rule 60(B)(8) requires the party to file their motion “within a reasonable time” and “allege a meritorious claim or defense.” Id. T.D. and the State do not dispute that the court erred by failing to comply with the Juvenile Waiver Statute; they disagree on the effect of that error.
We first hold that T.D. is not entitled to relief under Rule 60(B)(6) because a violation of the Juvenile Waiver Statute renders a judgment entering an agreed delinquency adjudication voidable rather than void. Accordingly, when the statute is violated, Rule 60(B)(8) is the proper vehicle for a juvenile to collaterally attack their adjudication. We then hold that T.D. is entitled to relief under Rule 60(B)(8). The State concedes T.D.’s motion was timely, and we conclude he demonstrated a meritorious claim by showing that the trial court did not follow the Juvenile Waiver Statute’s heightened protections. Because the State has failed to establish that T.D.’s waiver was nevertheless valid under the statute before the court accepted his admission, the trial court abused its discretion in denying T.D.’s motion for relief from judgment.
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The State asserts that because the trial court had both personal and subject matter jurisdiction, T.D.’s agreed delinquency adjudication “cannot be considered void.” T.D. concedes that the court had both personal and subject matter jurisdiction, but he argues the judgment is void because the court lacked authority to find him delinquent without first securing a valid waiver of his rights. We partially agree with both parties. A judgment is void when the issuing court lacks personal jurisdiction, subject matter jurisdiction, or the authority to render the judgment. But a court’s failure to comply with the Juvenile Waiver Statute falls outside of that scope because, despite the statutory violation, the court still has the authority to adjudicate the juvenile as a delinquent.
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Given the special caution afforded to juvenile admissions, a trial court’s failure to comply with the Juvenile Waiver Statute is particularly alarming. But that failure does not mean the court lacks the legal authority under any set of circumstances to adjudicate a juvenile as a delinquent. Indeed, nothing in the juvenile code prohibits a court from entering judgment on an agreed delinquency adjudication despite an invalid waiver of rights. Thus, violations of the Juvenile Waiver Statute do not render a subsequent delinquency adjudication void; they render it voidable because the error can be cured if challenged.
As a result, Trial Rule 60(B)(8) is the proper vehicle for juveniles to collaterally attack an adjudication based on an invalid waiver of rights. See G.B., 715 N.E.2d at 954. When relief is granted under this rule, the juvenile will have an opportunity to reevaluate whether to admit to the allegations raised in the delinquency petition or to proceed to fact-finding. Because the trial court’s judgment here was voidable, the court did not err in denying T.D.’s motion for relief under Trial Rule 60(B)(6). We next consider whether the court erred in denying T.D.’s motion under Rule 60(B)(8).
Trial Rule 60(B)(8) permits a party to obtain relief from judgment for “any reason” other than those set forth in other subsections of the rule that are not relevant here. T.R. 60(B)(8). To be entitled to relief under this rule, the movant must file their motion “within a reasonable time” and “allege a meritorious claim or defense.” Id. Additionally, our precedent requires the moving party to “demonstrate some extraordinary or exceptional circumstances justifying equitable relief.” Collier, 61 N.E.3d at 268 (collecting cases). Having abandoned any challenge to the timeliness of T.D.’s motion, the State asserts that T.D. is not entitled to relief because he has failed to show either a meritorious claim or exceptional circumstances. We disagree.
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Yet, the State maintains that the waiver was nevertheless valid under the Juvenile Waiver Statute because T.D. and Mother watched a video advisement before each hearing that explained his rights. We acknowledge T.D.’s counsel confirmed that, before the detention hearing, T.D. was advised of his rights by video and counsel informed Mother of T.D.’s rights. But that hearing took place three weeks before the hearing at which T.D. entered his admission. Additionally, such outside-the courtroom video advisements alone are insufficient to comply with the Juvenile Waiver Statute—the court must also personally question the juvenile and his parent, if present, on the record as to whether both understand and voluntarily waive the juvenile’s rights. N.M. v. State, 791 N.E.2d 802, 806–07 (Ind. Ct. App. 2003); Bridges, 299 N.E.2d at 618. That did not happen here. Finally, we acknowledge, as the trial court pointed out, that T.D. was represented by counsel “at every stage of the juvenile proceedings.” But, under the statute, simply being represented by counsel does not establish that T.D. knowingly and voluntarily waived each of the rights conferred on him through state or federal law. See D.D.B. v. State, 691 N.E.2d 486, 487 (Ind. Ct. App. 1998).
To summarize, T.D. met his burden for relief under Trial Rule 60(B)(8) by making a prima facie showing that the trial court failed to comply with the Juvenile Waiver Statute before accepting his admission. And the State did not present any evidence establishing that T.D.’s waiver was nevertheless valid under the statute. As a result, the trial court abused its discretion by denying his motion for relief from judgment.
For these reasons, we reverse the trial court’s judgment and remand with instructions to hold a hearing during which T.D. either admits to the allegations raised in the delinquency petition after the court complies with the Juvenile Waiver Statute or proceeds to fact-finding.
Massa, Slaughter, Goff, and Molter, JJ., concur.