R.r., Appellant v. State of Indiana, Appellee

Summary

The court reversed R.R.'s delinquency adjudication because the juvenile waiver-of-rights statute did not authorize waiver of his presumed right to attend the fact-finding hearing when he was absent, unrepresented by counsel for purposes of waiver, unemancipated, and had not joined in a waiver. The court assumed without deciding that due process guarantees juveniles a right to be present at such hearings and resolved the case on statutory grounds. Justice David, dissenting, would have recognized the constitutional right and held that R.R.'s conduct constituted a valid waiver.