In re Dahl

Brief Fact Summary.

Dahl appealed the decision of the trial court to charge his as an adult after he murdered a man at the age of seventeen.

Synopsis of Rule of Law.

A juvenile under the age of eighteen should be tried as a juvenile unless the defendant cannot be reformed by his nineteenth birthday or the defendant is a danger to the public.

Facts.

Dahl shot a man at the age of seventeen and was tried for first-degree murder in juvenile court. The county court assembled a three-judge panel that determined Dahl should be tried as an adult because the community was fearful of their execution if Dahl was freed. The county court did not provide an analysis as to Dahl’s state of mind. The appellate court affirmed and Dahl appealed to the Supreme Court of Minnesota to be tried as a juvenile.

Issue.

Has a state proven by clear and convincing evidence that a juvenile should be tried as an adult if the court did not provide any psychological or prior criminal history of the juvenile?

Held.

No. The state decided to try Dahl as an adult because of his age and the harshness of the crime. The way by which the trial court reached their decision to try Dahl as an adult does not constitute clear and convincing evidence.

Discussion.

The state did not establish by clear and convincing evidence that Dahl was a threat to public safety or that he could not be rehabilitated by his nineteenth birthday because the state did not evaluate Dahl’s psychological state or criminal history. Dahl must be tried as a juvenile without the introduction of clear and convincing evidence.