Justices: court could impose only 1 juvenile commitment

The Indiana Supreme Court has issued an opinion affirming that a juvenile may not be sentenced to both a determinate and indeterminate commitment. While the Indiana Court of Appeals had reached the same conclusion, the two courts differed in interpreting sections of Indiana Code Section 31-37-19 that address sentencing and dispositional decrees for juveniles.

In D.C. v. State of Indiana, No. 49S02-1102-JV-116, 14-year-old D.C. was sentenced to a determinate commitment of two years in the Department of Correction, followed by an indeterminate commitment “until the age of 21 unless sooner released by the DOC.”

The Court of Appeals had found that the juvenile court erred when it issued both a determinate and indeterminate sentence. After reviewing Indiana Code 31-37-19-10 and 31-37-19-6, the COA held that D.C. should have been sentenced to a determinate commitment under section 10.

But the Supreme Court held that the juvenile court has the discretion to determine which type of commitment is most appropriate and remanded to the court to determine whether D.C. should be sentenced under section 6 or 10.