J Q R v. State of Indiana

Summary

The Indiana Supreme Court held that a parent has an interest adverse to a juvenile when the evidence shows the parent may personally benefit from waiving the juvenile’s rights to the juvenile’s detriment. Because the father faced evidence of his own drug activity, the State failed to prove that the statutory no-adverse-interest requirement was satisfied for either waiver, making admission of the juvenile’s statements erroneous. The error was harmless because independent text messages substantially established the juvenile knew the pills contained fentanyl, so the adjudication was affirmed.