J.G.N. v. State
In a juvenile delinquency appeal from a BOLEO adjudication, the Sixth District struck probation condition 6(a) (no association with persons designated by the juvenile probation officer or parent/guardian) as failing all three Biller factors, but upheld condition 6(b) (no association with anyone under DJJ or DOC supervision) as reasonably related to future criminality. The court rejected (as both waived for inadequate briefing and meritless) overbreadth, vagueness, and separation-of-powers attacks on 6(b), reading an implicit knowledge requirement into the condition under Demott.
Key facts
- J.G.N., a juvenile, was adjudicated delinquent (BOLEO) and subjected to probation conditions including restrictions on association with persons designated by the probation officer or parent/guardian, and with anyone under Department of Juvenile Justice or Department of Corrections supervision.
- The trial court imposed both association conditions as special probation conditions; J.G.N. appealed, challenging their validity under the Biller factors and on constitutional grounds including overbreadth, vagueness, and separation of powers.
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Why it matters
This is a useful roadmap for litigating juvenile (and adult) special probation conditions: it applies Biller condition-by-condition, explains the relationship between Biller and overbreadth/abuse-of-discretion review… — full analysis with a trial
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