Juvenile’s waiver of his Miranda rights was not knowing, intelligent, and voluntary because of his demonstrated lack of maturity, the fact that he was not advised of the crime and possible consequences, and his minimal consultation with a parent.
Juvenile
State v. N.B., No. 19A-JV-1659, __ N.E.3d __ (Ind. Ct. App., Jan. 10, 2020).
A juvenile court has subject matter jurisdiction to entertain a delinquency petition and waive a defendant to adult criminal court but does not have jurisdiction to adjudicate a defendant over age twenty-one a delinquent child and enter a disposition.
In re Paternity of M.A.M., No. 19A-JP-771, __ N.E.3d __ (Ind. Ct. App., Dec. 11, 2019).
Prosecutor can pursue paternity proceedings at alleged father’s behest outside the two-year statute of limitations.
A.M. v. State, No. 19S-JV-603, __ N.E.3d __ (Ind., Nov. 12, 2019).
A court should evaluate a juvenile’s claim of ineffective counsel in a delinquency disposition-modification hearing by using a due process standard; it should consider counsel’s overall performance to determine if the child received a fundamentally fair hearing resulting in a disposition that served his best interests.
C.S. v. State, No. 19S-JV-137, __ N.E.3d __ (Ind., Oct. 1, 2019).
Ind. Admin. Rule 14(B) permits remote participation in juvenile disposition-modification hearings where the parties have agreed or where the court issues a good cause order based on the factors listed in the rule including the child’s best interest.