State v. P.S.
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The Court of Appeals vacated the disposition imposed by the district court in three juvenile matters, holding that the language in State v. J.R., 191 A.3d 1157 (Me. 2018), could be read to suggest that a court imposing an indeterminate commitment of a juvenile to a Department of Corrections facility must specify a commitment no shorter in duration than up to the juvenile's eighteenth birthday, and the trial court here may have proceeded under such a belief.
In this consolidated appeal, P.S. argued that the district court abused its discretion in ordering that he be committed to Long Creek Youth Development Center for an indeterminate period up to age eighteen. The Court of Appeals noted that, once the district court decided to commit P.S. to Long Creek, it may have felt compelled to order him committed up to his eighteenth birthday. The Court then acknowledged that its language in J.R. may have contributed to such a belief and clarified that the language of J.R. does not constrain a juvenile court's discretion to impose a shorter period of indeterminate commitment than up to a juvenile's eighteenth birthday so long as that commitment is for at least one year. Accordingly, the Court vacated the judgment and remanded the matter.
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