## Facts

- In May 1990, J.M., age 10, was adjudicated delinquent after cashing a forged check.
- J.M. successfully completed probation for the 1990 offense and was discharged.
- In October 1991, J.M. was again adjudicated delinquent for intentional damage to property in the second degree.
- On November 6, 1991, the juvenile court ordered an indefinite term of probation requiring J.M. to be law-abiding and not violate any local, state, or federal laws.
- In the 1991 delinquency matter, the juvenile court also placed J.M. in the custody of his grandparents, while granting visitation to his parents.
- Over the following years, J.M. remained on probation and custody shifted between his parents and grandparents at different times, with J.M. ultimately living with his grandparents.
- In December 1994, the juvenile court found J.M. had satisfactorily completed probation, discharged him from probation, and terminated juvenile-court jurisdiction.
- After jurisdiction was terminated, the juvenile court held a later hearing in June 1995 addressing living arrangements.
- At that hearing, J.M. testified that he wanted to remain with his grandparents because he was happy there, doing well in school, and feared he would return to delinquent behavior if he went back to his parents’ home.
- A court-ordered home study did not find J.M.’s parents unfit.
- J.M. appealed after the juvenile court terminated its jurisdiction.

## Issues

1. After finding a juvenile delinquent had satisfactorily completed the conditions of probation, could the juvenile court terminate delinquency-based jurisdiction even though the juvenile wanted the court to remain involved to keep him placed with his grandparents?

## Decision

- The court affirmed.
- The juvenile court properly discharged J.M. from probation after finding he had satisfied the probation conditions.
- The juvenile court properly terminated its jurisdiction once the delinquency proceeding no longer supplied a basis for continued supervision.
- The juvenile court could not keep delinquency jurisdiction in place solely to preserve a custody arrangement preferred by the child where there was no finding that the parents were unfit and no new delinquency basis for court involvement.

## Legal Principles

- Juvenile-court authority in delinquency matters is statutory; the court’s power to supervise a child depends on an existing statutory ground for jurisdiction.
- When the court determines probation conditions have been satisfied, it may discharge the juvenile from probation and end delinquency supervision.
- A child’s placement preference and generalized fears about future misconduct, without new delinquent acts or another statutory basis, do not authorize extending delinquency jurisdiction.
- Custody disputes between fit adults are not resolved by continuing a delinquency case after its rehabilitative purpose has been completed; they must be addressed through the appropriate non-delinquency procedures.

## Conclusion

In the Matter of J.M. holds that once J.M. completed the terms of his delinquency probation, the juvenile court acted properly in discharging him and terminating jurisdiction, and it lacked authority to keep the delinquency case open merely to maintain J.M.’s preferred placement with his grandparents absent a new statutory basis for continued juvenile-court control.


In the Matter of J.M., 546 N.W.2d 383 (1996)