In re Dahl
Minnesota Supreme Court
278 N.W.2d 316 (1979)
Dahl (defendant), seventeen with no prior criminal history besides a reckless driving charge, shot a man and left him for dead, then admitted his actions and was charged in juvenile court with first-degree murder; a petition to refer him to adult criminal court followed amid community fear, supported by evidence Dahl used marijuana and had written a note about needing to "terminate" local citizens, but the three-judge panel that ordered adult prosecution gathered no psychological data about Dahl's state of mind, and the court of appeals affirmed. Dahl appealed to the state supreme court, arguing he should be tried as a juvenile.
Whether the state has proven by clear and convincing evidence that a juvenile should be charged as an adult where its analysis contained no psychological data or consideration of prior criminal history.