C.S. v. State
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The Supreme Court affirmed the judgment of the trial court making two teenagers wards of the Indiana Department of Correction, holding that the teenagers failed to show that their remote participation in their hearings resulted in fundamental error but closed this opinion with guidance so that this procedural story would not be repeated.
The teenagers in this case each appeared by Skype at a hearing to decide whether their juvenile dispositional decrees should be modified to make them wards of the Department of Correction. The teenagers did not object to participating remotely, but nothing in the record indicated that they agreed to do so or that the trial court found good cause for the remote participation. Both teenagers were made wards of the Department of Correction after the hearings. The Supreme Court affirmed, holding (1) Indiana Administrative Rule 14(B) governs the use of telephones and audiovisual telecommunication tools in juvenile disposition-modification hearings; but (2) because the teenagers failed to object to the court's noncompliance with Rule 14(B) and failed to demonstrate fundamental error, the teenagers waived the issue.
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