J.I.S. v. State

Appellant, a juvenile, appeals the trial court’s denial of his motion for credit for time he spent in secured detention, awaiting disposition. Appellant’s disposition (as distinguished from a sentence) required he be committed to a high risk program. Appellant could complete his program in nine months, eighteen months, or longer, depending upon how he responded. Thus, his commitment was for an indeterminate length of time. We affirm for two reasons.

We begin by noting that, as a practical matter, since juveniles are committed for indeterminate lengths of time, it is “generally impossible to…