N.N.R. v. Grice
A juvenile on postcommitment probation, found incompetent to proceed and committed to DCF for restoration services, was nevertheless held in secure detention past her placement date because DCF had not yet located an appropriate community placement. The Second DCA granted her habeas petition, holding that section 985.24(3)(d) prohibits secure detention based solely on the unavailability of a more appropriate facility, and distinguished the Fourth District's A.T. v. State, which had allowed extended detention of an incompetent juvenile as a 'continuance for cause' under section 985.26(4).
Key facts
- N.N.R., a juvenile found incompetent to proceed, was committed to DCF for restoration services but remained in secure DJJ detention past her placement date because DCF had not yet located an appropriate community placement.
- The trial court justified continued secure detention under section 985.26(4)'s 'continuance for good cause' provision, citing the unavailability of a more appropriate facility.
- +2 more key facts with a free trial
Why it matters
This opinion gives juvenile defense counsel a strong statutory tool to challenge prolonged secure detention of incompetent juveniles who are stuck awaiting SIPP or other DCF placement, a recurring practical problem… — full analysis with a trial
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