State ex rel. R.S. v. Trent

George Trent (defendant) was a 16-year-old juvenile who was incarcerated at an industrial school for boys in connection with his adjudication of delinquency for breaking and entering. Trent had a long history of delinquent acts and had spent much of his life in detention, mental-health, and correctional facilities. Trent had several diagnoses, including organic brain syndrome and emerging antisocial personality disturbance. After Trent had been at the industrial school for almost one year, he was released on the superintendent’s recommendation that continuing to incarcerate Trent at the industrial school would not help him. Trent was released, but three days later, he was arrested and jailed for stealing a car. Trent was released from jail after two days but was arrested again three days later for stealing a motor home. Trent was adjudged delinquent again and sent back to the same industrial school for boys. Trent sought a writ of habeas corpus and a writ of mandamus to force the circuit court to send him to a suitable residential treatment center that could focus on his rehabilitation. Trent argued that his incarceration was not lawful, because the court did not afford him the least restrictive dispositional option. Trent argued that he was entitled to receive the treatment necessary to meet his therapeutic needs. The circuit court had made a finding that there was no less restrictive alternative than incarcerating Trent at the industrial school. However, the court did not list any particular facts in its order supporting its conclusion, although there were exhibits on the record that would support such a conclusion.