Cases | In re Arnold M., 471 A.2d 313 (Md. 1984) | 2018
The juvenile defendants escaped from a State residential treatment facility for emotionally disturbed youths and subsequently assaulted and injured the seventy-four-year-old victim during an attempted robbery. The defendants were found to have committed delinquent acts as charged in juvenile petitions. The State’s Attorney filed for restitution on behalf of the victim, who had incurred $318.40 in medical expenses, seeking payment from the defendants and from the State on the theory that the State stood in loco parentis to the juveniles. The juvenile court entered judgment for the victim against the juveniles and the State in the amount of $318.40. The State appealed and the Court of Appeals granted certiorari before the intermediate court’s decision. The Court of Appeals held that holding the State to be in loco parentis to the juveniles would extend the statute well beyond its plain meaning by requiring the State to indemnify losses of all victims of delinquent acts perpetrated by juveniles committed to State institutions. The court found no legislative intent for such a result. The judgment was reversed.