A Case Regarding Admissibility of Evidence in Juvenile Delinquency

In J.B. v. State of Indiana, the Indiana Court of Appeals reversed a juvenile delinquency adjudication based on the improper admission of hearsay evidence. This case involved whether J.B., a juvenile, was denied due process when the court admitted a videotaped interview of the alleged victim, A.W., as evidence.

Case Background

J.B. and A.W., half-siblings, were living with their maternal grandmother in early 2021 when A.W. disclosed inappropriate sexual contact between herself and J.B. Soon after, A.W. recanted her statement, saying it was made in a fragile mental state. However, the State continued to pursue a delinquency petition against J.B., relying heavily on a videotaped interview of A.W. conducted at the Child and Family Advocacy Center (CFAC).

At the delinquency hearing, J.B. raised a general objection to the admission of the CFAC interview, but the trial court admitted it. Consequently, J.B. was found delinquent and placed on supervised probation.

Appeal and Legal Issues

J.B. appealed the trial court's ruling, claiming that the videotaped interview should not have been admitted under Indiana’s hearsay rules. The Indiana Court of Appeals reviewed the case and found three key issues:

1. Hearsay Exception for Former Testimony: The court ruled that the CFAC interview did not meet the requirements for former testimony under Indiana Rule of Evidence 804(b)(1). J.B. had no opportunity to cross-examine A.W., and the interview was not conducted under oath.
2. Hearsay Exception for Statements Against Interest: The court rejected the State's argument that A.W.'s statements were admissible as statements against interest. Indiana Rule 804(b)(3) explicitly excludes statements implicating both the declarant (A.W.) and the accused (J.B.).
3. Violation of Due Process: The court concluded that the admission of the CFAC interview violated J.B.'s constitutional right to due process because it was the only evidence demonstrating the elements of the delinquent act. Without the ability to cross-examine A.W., J.B. was deprived of a fair trial.

Court’s Decision

The Indiana Court of Appeals found that the trial court committed fundamental error by admitting the CFAC interview, violating J.B.'s right to a fair trial. As a result, the court reversed J.B.’s delinquency adjudication and remanded the case for further proceedings.