Court: punitive penalty not allowed

A juvenile court erred when it found a juvenile in civil contempt of court and imposed an additional term of confinement as a result, the Indiana Court of Appeals has ruled.

In K.L.N. v. State of Indiana, No. 71A03-0708-JV-411, K.L.N., a juvenile, had appealed the juvenile court’s decision to impose an additional term of confinement against him for being found in contempt of court. K.L.N. was confined to a secure facility for 120 days and often did not follow the rules. As a result, he had some privileges taken away by the facility, and the juvenile court modified the terms of his dispositional decree to include an order that he must follow the rules of the facility.

After breaking more rules and being found in indirect contempt of court, the juvenile court added 77 days to his term of detention.

Although K.L.N. was released from commitment and probation, closing his case before the appeals process was finished, authoring Chief Judge John Baker wrote in a footnote the court would still rule on the issue because it is a question of public interest that is likely to recur.

The Court of Appeals ruled the juvenile court erred by holding K.L.N. in contempt and lengthening his term of confinement. The juvenile court had ordered that for every day of his original confinement in which he was well-behaved, one day would be subtracted from the contempt detention.

A penalty imposed by a court for an act of civil contempt must be coercive or remedial rather than punitive in nature. The judges looked to caselaw outside of Indiana for guidance on the subject. The Washington Court of Appeals found a juvenile court erred when it ordered a teen, who had numerous unexcused absences from school, to attend school or else be found in contempt and forced to serve detention for each violation. After being found in contempt on three separate occasions for violating the order, the juvenile court ordered the teen to serve two days of secured detention. The nature of the sanctions were not remedial but punitive because the teen could not immediately satisfy the conditions of the court and remained in jeopardy of incarceration.

Because the juvenile court failed to provide a genuine means for the teen to purge the contempt, the sanction was punitive, imposed, and suspended on conditions, thus, it was criminal in nature and not civil, wrote Chief Judge Baker. Similarly, the condition put on K.L.N. by the juvenile court to follow the rules for the rest of his detention and allowing days to be subtracted for previous good behavior was not within K.L.N.’s capacity to complete at the time the sanctions were imposed.

Indiana statute has not allowed juvenile courts to have authority to “micro-manage” the detention of a juvenile delinquent, he wrote. A trial court would not have the authority to lengthen an inmate’s sentence for failure to abide by prison rules. Thus, it is up to the detention facility to institute a punishment for bad behavior, not the courts.

The appellate court found the juvenile court erred and reversed the decision.