## Facts

- In June 1992, the Sarpy County Attorney filed a petition in juvenile court seeking a finding that J.A. was a delinquent child based on conduct amounting to disturbing the peace.
- J.A. admitted the conduct, and the juvenile court took jurisdiction over her.
- The juvenile court ordered J.A. to complete a 30-day evaluation at the Nebraska Youth Development Center in Geneva, Nebraska (Geneva).
- After the evaluation, the juvenile court held (and continued) dispositional hearings, apparently to monitor J.A.’s progress.
- The court imposed terms and conditions, including that J.A. obey laws and ordinances and abstain from drugs and alcohol.
- Within a few months, J.A. violated the court’s orders: she was arrested after fighting with her mother, had been drinking alcohol and sniffing paint, and was found with an elevated blood-alcohol content.
- At a later dispositional hearing, J.A. admitted the misconduct.
- The juvenile court committed J.A. to Geneva but did not give explicit reasons on the record for choosing that placement.
- J.A. appealed, claiming the juvenile court erred by committing her to Geneva without articulating its reasons.

## Issues

1. Did the juvenile court commit reversible error by ordering J.A.’s commitment to the Nebraska Youth Development Center at Geneva without stating on the record its reasons for that commitment?
2. Did the juvenile court abuse its discretion, on this record, by selecting commitment to Geneva as the disposition?

## Decision

- The Nebraska Supreme Court affirmed the juvenile court’s dispositional order.
- The court held that the lack of an express on-the-record statement of reasons for committing J.A. to Geneva did not, by itself, require reversal where the record supported the disposition.
- The court concluded the juvenile court acted within its statutory authority and did not abuse its discretion in committing J.A. to Geneva in light of her repeated violations and the court’s prior, less restrictive efforts.

## Legal Principles

- Juvenile dispositions are reviewed for abuse of discretion; an appellate court will not disturb the disposition unless the juvenile court’s decision was untenable or unreasonable based on the record.
- Under Nebraska’s juvenile code, the juvenile court has broad authority at disposition to select a placement or commitment that addresses the juvenile’s needs and protects the public.
- A dispositional order is not automatically reversible simply because the juvenile court did not separately recite detailed reasons for selecting a particular placement, so long as the record provides a supported basis for the choice.

## Conclusion

In *In re Interest of J.A.*, the Nebraska Supreme Court affirmed a juvenile court’s decision to commit a delinquent juvenile to the Youth Development Center at Geneva after repeated violations of dispositional conditions, holding that the commitment could stand even though the juvenile court did not expressly state its reasons on the record, because the record supported the court’s exercise of discretion.


In re Interest of J.A., 510 N.W.2d 68 (1994)