In re D.F.B

Brief Fact Summary.

D.F.B. appealed the decision to be tried as an adult after he murder his parents and siblings with an axe at the age of sixteen.

Synopsis of Rule of Law.

The state must establish by clear and convincing evidence that a juvenile cannot be rehabilitated by his nineteenth birthday or he poses a danger to the public in order for a juvenile to be tried as an adult.

Facts.

D.F.B. suffered from a severe depressive disorder and was charged for murder after he killed his parents and siblings with an axe. The trial court decided to charge D.F.B. as a juvenile because the state did not prove by clear and convincing evidence that D.F.B. was a danger to the public and that his depressive order could not be remedied by his nineteenth birthday. The state succeeded in the appellate court because they introduced a multi-factorial analysis constituting clear and convincing evidence of D.F.B.’s ability to be rehabilitated by his nineteenth birthday and his danger to the public. D.F.B. appealed to Minnesota’s Supreme Court.

Issue.

D.F.B. suffered from a severe depressive disorder and was charged for murder after he killed his parents and siblings with an axe. The trial court decided to charge D.F.B. as a juvenile because the state did not prove by clear and convincing evidence that D.F.B. was a danger to the public and that his depressive order could not be remedied by his nineteenth birthday. The state succeeded in the appellate court because they introduced a multi-factorial analysis constituting clear and convincing evidence of D.F.B.’s ability to be rehabilitated by his nineteenth birthday and his danger to the public. D.F.B. appealed to Minnesota’s Supreme Court.

Held.

Yes. The state’s analysis established by clear and convincing evidence, through the factors introduced, that D.F.B. should be tried as an adult in the criminal court.

Discussion.

A juvenile cannot be tried as an adult just because he committed a terrible crime. The defendant has to be a danger to public safety and the defendant’s threat has to be proven by clear and convincing evidence. Among other factors, the state’s multifactorial analysis included doctor’s recommendations, the defendant’s threat to society, and the severity of the crime. The analysis provided by the state proved that D.F.B. would not be reformed by his nineteenth birthday and that he was a threat to the public.