Indiana Supreme Court

A.M. v. State of Indiana

November 12, 2019

Summary

The court held that a juvenile’s ineffective-assistance claim arising from a disposition-modification hearing is governed by a Fourteenth Amendment due-process standard rather than the Sixth Amendment standard. The court asks whether counsel’s overall performance ensured a fundamentally fair hearing resulting in a disposition serving the juvenile’s best interests, and it affirmed because counsel’s performance satisfied that standard. The court did not decide what standard governs ineffective-assistance claims arising from the adjudicative or initial dispositional phases.