In the Interest of N.L., a Minor

Summary

The Pennsylvania Superior Court affirmed an order continuing juvenile court supervision over N.L., a dependent individual, after his twenty-first birthday. The court held that jurisdiction could continue because N.L.’s transition plan was not fully implemented or funded, including the absence of secured Social Security benefits. The court relied on Pennsylvania Rule of Juvenile Court Procedure 1631(e) and Interest of R.P. in concluding that approval of a transition plan requires more than merely developing the plan.

Holdings

1. A juvenile court is not automatically and irrevocably stripped of jurisdiction over a dependency proceeding when the dependent turns 21.
2. The juvenile court properly continued jurisdiction because N.L.'s transition plan was not complete or feasible without a secured source of income and funding for the adult placement.
3. The appeal was not dismissed as moot because the jurisdictional issue was capable of repetition and apt to elude appellate review.

Questions Presented

1. Whether a juvenile court automatically loses jurisdiction over a dependency proceeding when the dependent turns 21.
2. Whether the juvenile court could continue supervision after N.L.'s twenty-first birthday because the transition plan lacked secured income and was not adequately funded.
3. Whether the appeal should be dismissed as moot after the juvenile court later accepted the transition plan and terminated supervision.

Disposition

affirmed