A juvenile court cannot impose a jail term on someone over the age of 18 but under 21 for violating probation related to a crime that occurred when the defendant was a juvenile, the Pennsylvania Superior Court has ruled.
The appeals court in In re J.M. said the Juvenile Act is clear that juveniles cannot be placed in an adult correctional facility. The panel then needed to determine if J.M., who was 18 at the time a Clearfield County Common Pleas Court judge sentenced him to 10 days to one year in jail for a probation violation, was a juvenile within the meaning of the statute.
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