In re the Welfare of J.H.
Supreme Court of Minnesota
844 N.W.2d 28 (Minn. 2014)
Seventeen-year-old J.H. (defendant) was present when a minor, G.K., was gang-raped; under Minnesota's six-factor public-safety test for adult certification, the juvenile court found all factors but J.H.'s lack of a prior record favored certification, gave written findings on each factor, and explicitly stated it gave greater weight to the offense's seriousness and J.H.'s lack of prior record as statutorily required, certifying J.H. for adult trial. The court of appeals reversed, finding the juvenile court gave too much weight to the offense's seriousness and too little to J.H.'s clean record; the state appealed.
In determining whether a minor will be certified as an adult, is a juvenile court required to (1) expressly weigh the seriousness of the offense and the prior record of delinquency separately from the other public safety factors and (2) specifically delineate how these two factors implicated its certification determination?