## Facts

- Minnesota enacted two juvenile-justice amendments effective January 1, 1995: (1) an extended jurisdiction juvenile (EJJ) scheme allowing juvenile jurisdiction until age 21 with a juvenile disposition plus a stayed adult sentence, and (2) presumptive adult certification for certain offenses committed by 16- and 17-year-olds, rebuttable only by clear and convincing evidence that juvenile-court retention serves the public interest.
- J.T.K., age 16, was charged by delinquency petition with terroristic threats and second- and third-degree assault arising from conduct on January 19, 1995.
- The prosecutor sought EJJ designation for J.T.K.
- L.J.S., age 17, faced petitions alleging first-degree burglary, aggravated robbery, and possession of a shotgun (March 3, 1995), and robbery, criminal damage to property, and fleeing police (March 12, 1995).
- The district court applied the presumptive adult-certification provision to L.J.S.
- In both matters, the juveniles raised constitutional challenges to the 1994 amendments; the district courts rejected the challenges but certified constitutional questions for appellate review.
- The appellate court consolidated the certified questions.

## Issues

1. Whether the EJJ statute violates substantive or procedural due process by extending juvenile jurisdiction while exposing the juvenile to a stayed adult sentence.
2. Whether the presumptive adult-certification statute violates procedural due process by creating a rebuttable presumption and placing on the juvenile a clear-and-convincing burden to show juvenile-court retention serves the public interest.
3. Whether either statute violates equal protection by treating 16- and 17-year-olds charged with specified serious offenses differently from other juveniles.

## Decision

- The court held both the EJJ statute and the presumptive adult-certification provision constitutional.
- The court answered the certified questions in the negative and affirmed the district courts’ rejection of the constitutional challenges.
- The court concluded that the statutory schemes preserve judicial decision-making through notice, hearing, and an opportunity to contest EJJ designation or rebut presumptive certification.

## Legal Principles

- The legislature has broad authority to define juvenile-court jurisdiction and transfer mechanisms, subject to constitutional limits.
- Procedural due process is satisfied where the juvenile receives notice and a hearing and the court ultimately determines whether EJJ designation is appropriate or whether presumptive certification is rebutted.
- A statutory rebuttable presumption requiring the juvenile to produce clear and convincing evidence may be constitutionally permissible in the juvenile-transfer context when tied to serious charged offenses and public-safety interests.
- The existence of a stayed adult sentence within an EJJ framework does not violate substantive due process when execution is contingent on future violations or new offenses rather than automatic.
- Age- and offense-based distinctions in juvenile prosecution generally are reviewed under rational-basis principles; such classifications are valid if reasonably related to legitimate state interests such as public safety, deterrence, and proportional sanctions.

## Conclusion

The court sustained Minnesota’s EJJ and presumptive adult-certification amendments, holding that the statutes’ burden allocation and conditional stayed adult sentencing structure do not violate due process and that the age- and offense-based classifications withstand equal protection review.


In re Welfare of L.J.S. & J.T.K., 539 N.W.2d 408 (Minn. Ct. App. 1995)