## Facts

- Milton Good Jr., a juvenile, was charged in juvenile court with aggravated robbery and possession of a firearm while committing a felony (a firearm specification).
- After Good’s arrest, the original complaint that was filed did not include a specification describing the type of firearm Good was alleged to have used.
- A hand-written note containing a firearm specification was found in the court file, but that note was not file-stamped and was not attached to the original complaint.
- The record reflected that, as a matter of routine practice, a typed complaint based on the original hand-written complaint (and containing any firearm specification) would typically be filed later.
- No typed complaint containing the firearm specification was found in Good’s file.
- At a January 19, 1996 hearing, the juvenile court verbally informed Good of the charges against him, including the firearm specification.
- At a January 30, 1996 hearing, the juvenile court informed Good of the possible consequences of the charges.
- Following the January 30 hearing, the juvenile court adjudicated Good delinquent on both the aggravated robbery charge and the firearm specification.
- Good appealed from the delinquency adjudication.

## Issues

1. Whether a juvenile may be adjudicated delinquent for a firearm specification when the filed complaint did not properly include the specification in the written paperwork, but the juvenile court gave the juvenile oral notice of the specification and its possible consequences before adjudication.

## Decision

- The appellate court affirmed the delinquency adjudication.
- The court concluded that the firearm-specification adjudication was not reversible error even though the written complaint record was incomplete, because Good received timely oral notice of the specification and was advised of the possible consequences before he was adjudicated delinquent.

## Legal Principles

- Due process in juvenile delinquency proceedings requires notice of the nature of the allegations sufficient to allow the child to prepare a defense.
- A defect or omission in the written charging paperwork relating to a specification does not require reversal where the child receives actual notice through the proceedings in time to respond and no unfairness is shown.
- When assessing notice, an appellate court may consider what the juvenile court communicated on the record at hearings, not only what appears on the face of a file-stamped complaint.

## Conclusion

In *In re Good*, the court affirmed a juvenile delinquency adjudication that included a firearm specification, holding that the absence of a properly filed written specification in the complaint papers did not warrant reversal where the juvenile court orally advised the child of the specification and the possible consequences before adjudication.


In re Good, 692 N.E.2d 1072 (1997)