The Maryland Court of Appeals recently ruled on the jurisdiction of juvenile courts in a case involving a twelve-year-old boy, D.E., who was charged with robbery and other offenses. The court determined that once a juvenile court has jurisdiction over a child, that jurisdiction does not end even if the court finds the child not involved in the more serious charge of robbery but involved in a lesser offense. This ruling is significant as it clarifies how juvenile courts handle cases involving children accused of crimes.

The case, known as In re: D.E. (Docket No. 59/25), arose from an incident where D.E. was accused of robbery and other lesser offenses. The ruling is particularly important for juvenile justice reform and could impact how similar cases are handled in the future.

Background

The parties involved in this case include the State of Maryland and D.E., a twelve-year-old boy. D.E. was charged with robbery, which is classified as a crime of violence, along with several lesser offenses stemming from the same incident. The incident occurred on February 13, 2024, when D.E. allegedly followed a woman, Kelly Drnec, and took her purse. After an adjudicatory hearing, a magistrate found D.E. not involved in the robbery but guilty of misdemeanor theft.

D.E. argued that the juvenile court lost its jurisdiction once the robbery charge was not sustained, as children under thirteen cannot be brought into juvenile court for misdemeanors alone. The case was initially heard in the Circuit Court for Baltimore City, where the magistrate ruled that jurisdiction had attached when the State filed the delinquency petition, and thus the court could proceed with the lesser charges.

The Ruling

The Maryland Court of Appeals ruled that the juvenile court is not divested of jurisdiction over a child between the ages of ten and twelve when it finds the child not involved in the alleged crime of violence but involved in a lesser offense from the same incident. Judge Killough, writing for the court, stated, “Jurisdiction attached when the State filed the delinquency petition, and nothing in the Juvenile Causes subtitle divested the court of that authority.”

The court explained that the jurisdiction of the juvenile court is established at the time of filing the delinquency petition and continues until the child turns twenty-one, unless terminated sooner. The ruling emphasized that a finding of not involved in a crime of violence does not terminate the court's jurisdiction over related offenses.

Impact

This ruling has significant implications for how juvenile cases are handled in Maryland. It clarifies that once a juvenile court obtains jurisdiction based on a crime of violence, it retains that jurisdiction even if the more serious charge is not sustained. This means that juvenile courts can address lesser offenses that arise from the same incident without losing their authority.

The ruling may also influence future cases involving juveniles accused of crimes, as it reinforces the idea that the juvenile justice system can continue to operate even when serious charges are not upheld. This could lead to more consistent handling of juvenile cases and ensure that children receive appropriate interventions, regardless of the outcome of the initial charges.

What's Next

It is unclear whether D.E. will appeal the ruling or if any related cases are pending. However, the court's decision may prompt discussions about further reforms in the juvenile justice system, particularly regarding how jurisdiction is defined and maintained.