J.W. v. State of Indiana

Slaughter, Justice.

We held in Tumulty v. State , 666 N.E.2d 394 (Ind. 1996), that an adult criminal defendant cannot challenge the validity of his guilty plea on direct appeal. He must, instead, pursue post-conviction relief and raise in that proceeding any claims of error concerning his plea.

At issue here is whether to extend Tumulty to the juvenile-law counterpart to a criminal plea-namely, an agreed delinquency adjudication. We hold that juveniles cannot immediately challenge on direct appeal any errors concerning their agreed adjudication. But because juveniles are not eligible for…