## Facts

- J.H., a juvenile, was charged by petition as a principal and accomplice with criminal sexual conduct, conspiracy to commit first-degree criminal sexual conduct, kidnapping, and a gang-related offense arising from the rape of a 14-year-old girl.
- The victim reported being taken to multiple parties in St. Paul, including one at an abandoned house, and identified several individuals as gang members.
- When the victim attempted to leave, she was forcibly taken into a bedroom, held down, and raped while multiple individuals were present.
- The victim reported that between six and eight individuals, including J.H., were in the bedroom during the rape.
- The State moved to certify J.H. for adult prosecution under Minn. Stat. § 260B.125; due to J.H.’s age and the charged offenses, a statutory presumption favored adult certification.
- After a three-day hearing, the juvenile court found J.H. did not rebut the presumption by clear and convincing evidence and ordered adult certification.
- The court of appeals reversed, concluding the juvenile court abused its discretion by failing to “expressly weigh” the two statutorily favored factors separately and to “specifically delineate” their impact on the certification decision.

## Issues

1. Under Minn. Stat. § 260B.125, subds. 3–4, must a juvenile court separately “expressly weigh” (a) seriousness of the alleged offense and (b) the juvenile’s prior delinquency record, apart from the other public-safety factors?
2. Must the juvenile court “specifically delineate” in its written order how those two factors affected its certification decision?
3. Did the juvenile court abuse its discretion in determining J.H. failed to rebut the presumption favoring adult certification by clear and convincing evidence?

## Decision

- The Minnesota Supreme Court reversed the court of appeals and reinstated the juvenile court’s adult-certification order.
- The court held the statute does not require the juvenile court to separately “expressly weigh” the seriousness and prior-record factors or to “specifically delineate” how those factors affected the outcome.
- The court held the juvenile court’s written findings satisfied Minn. Stat. § 260B.125 because they addressed each of the six public-safety factors and reflected the required greater weight for seriousness and prior record.
- Applying abuse-of-discretion review, the court concluded the certification decision was supported by the record and was not an abuse of discretion.

## Legal Principles

- Minn. Stat. § 260B.125 requires written findings on six public-safety factors when deciding whether to certify a juvenile for adult prosecution.
- The statute requires “greater weight” be given to the seriousness of the alleged offense and the juvenile’s prior delinquency record.
- The statute does not impose a formal requirement that the juvenile court separately weigh those two factors or provide a particularized explanation of their impact beyond written findings that address the factors and reflect the required weighting.
- When the statutory presumption favoring adult certification applies, the juvenile bears the burden to rebut the presumption by clear and convincing evidence.
- Appellate review of a certification decision is for abuse of discretion; a certification order should be affirmed if the court applied the statute, made adequate written findings, and the record supports the conclusion that the presumption was not rebutted.

## Conclusion

The Minnesota Supreme Court held that a juvenile court complies with Minn. Stat. § 260B.125 by making written findings on all six public-safety factors and giving greater weight to seriousness and prior record, without separately weighing or specially explaining those two factors; because the juvenile court’s findings and conclusion were supported by the record, adult certification was affirmed.


In re Welfare of J.H., 844 N.W.2d 28 (Minn. 2014)