Appellate court dismisses juvenile’s appeal of DOC commitment

The Indiana Court of Appeals has dismissed a teenager’s appeal of his commitment to the Indiana Department of Correction, finding that because the teenager has already been released, his appeal is moot.

In September 2014, then-14-year-old C.J. and three of his friends battered A.A., and C.J. was subsequently arrested and adjudicated as a delinquent for committing battery, a Class A misdemeanor if committed by an adult. At a dispositional hearing the following November, C.J. was placed on probation.

However, in the meantime, the state filed a delinquency petition against C.J. in October 2014, alleging that he had committed armed robbery, battery, criminal recklessness, dangerous possession of a firearm, carrying a handgun without a license and resisting law enforcement, each various felony and misdemeanor charges if committed by an adult. C.J. admitted to the robbery and dangerous possession of a firearm charge and was placed on probation with suspended commitment to the Department of Correction.

C.J. was also sent to Transitions Academy for five months, but was arrested again for an incident involving a gun shortly after his release. C.J. then failed two drug screens, so the juvenile court issued a dispositional order in April 2016 awarding wardship over C.J. to the DOC and ordering him to be placed in the DOC for 12 months.

After the juvenile court denied his emergency motion to stay his commitment, C.J. appealed in C.J. v. State of Indiana, 49A02-1605-JV-1032. However, C.J. was released from the DOC in October 2016, so the Indiana Court of Appeals issued a show cause order as to why the appeal should not be dismissed as moot.

In his response, C.J. argued that his appeal was not moot “due to possible negative collateral consequences he would face as a result of the DOC placement.” He further argued on appeal that the juvenile court had abused its discretion when it awarded wardship over him to the DOC.

But the appellate court failed to reach the merits of C.J.’s appeal because it found in a Tuesday opinion that the appeal was moot. Further, Judge Edward Najam wrote for the unanimous appellate panel that C.J.’s placement within the DOC did not involve a question of “great public interest,” so the court could not decide the case on its merits under the exception to the mootness rule.

The appellate court, therefore, rejected C.J.’s argument as to the “possible negative collateral consequences” and dismissed his case.