In re Gabriela A.

There has been a spate of recent Appellate Division opinions that have held that “Family Court may not ‘bootstrap’ a PINS adjudication onto one alleging juvenile delinquency by charging a PINS who absconds from a non-secure facility with conduct that, if committed by an adult, would constitute escape” (Matter of Daniel I., 57 AD3d 666, 667-668 [2d Dept 2008]), or obstructing governmental administration (see id. at 668), criminal mischief (see id.) or criminal contempt (see Matter of Edwin G., 296 AD2d 7, 12 [1st Dept 2002]; Matter of Jasmine A., 284 AD2d 452, 453 [2d Dept 2001]; Matter of…