Summary
The New Hampshire Supreme Court held that when a juvenile has consented to extended jurisdiction and validly revokes that consent, the court must close the case under RSA 169-B:4, IV. The court concluded that RSA 169-B:4, V, which permits retention of jurisdiction in certain circumstances, applies only in the circumstances governed by paragraph III and does not authorize continued jurisdiction after a valid revocation under paragraph IV.
Holdings
- When a court's extended jurisdiction rests on the juvenile's consent under RSA 169-B:4, II, closure of the case after a valid revocation of consent is controlled exclusively by RSA 169-B:4, IV. Because paragraph IV requires the court to close the case when the juvenile validly revokes consent, paragraph V does not authorize continued jurisdiction in that circumstance.
Questions Presented
- Whether RSA 169-B:4 permits a court that obtained extended jurisdiction through a juvenile's consent under paragraph II to retain jurisdiction under paragraph V after the juvenile validly revokes consent under paragraph IV.
Disposition
reversed
Cases Cited (4)
- Comeau v. Vergato, 149 N.H. 508, 510 (2003)(followed)
- In re Eric C., 124 N.H. 222, 224 (1983)(followed)
- In re Russell C., 120 N.H. 260, 264 (1980)(followed)
- In re Russell C., 120 N.H. 260, 268 (1980)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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