## Facts

- T.C.J., age 17 and a former student, went to Park Center High School with J.H., who sought enrollment materials.
- A teacher repeatedly told T.C.J. and J.H. to leave school property after recognizing T.C.J. was no longer a student.
- After the two fled through doors the teacher said were off-limits, the teacher pursued them off school property.
- The teacher told them to return to the school to resolve the matter “the easy way or the hard way” and grabbed J.H. by the shirt.
- The teacher testified that J.H. began choking him and that T.C.J. punched him in the head; T.C.J. testified he struck the teacher to protect J.H. from the teacher’s choking.
- The teacher sustained multiple injuries; neither juvenile was injured.
- T.C.J. was charged with first-degree assault, a charge triggering presumptive adult certification, but the district court denied adult certification and designated the case as extended-juvenile-jurisdiction (EJJ).
- A jury acquitted T.C.J. of first-degree assault but found him guilty of third-degree assault; the court imposed a juvenile disposition and a stayed adult sentence under the EJJ statute.

## Issues

1. Whether the district court abused its discretion in jury-related rulings, evidentiary rulings, or jury instructions (including self-defense/defense-of-another).
2. Whether the evidence was sufficient to support the third-degree assault adjudication.
3. Whether an EJJ disposition requiring a stayed adult sentence, imposed following juvenile-court procedures, complied with constitutional requirements, including jury-trial protections and equal protection.

## Decision

- The court affirmed the delinquency adjudication for third-degree assault, rejecting claims of reversible error in evidentiary rulings and jury instructions.
- The court held the evidence, viewed in the light most favorable to the verdict, was sufficient for a rational jury to find third-degree assault and to reject the defense-of-another theory.
- The court modified the disposition by vacating the stayed adult sentence while leaving the juvenile disposition and EJJ adjudication intact.

## Legal Principles

- Evidentiary rulings are reviewed for abuse of discretion and are reversed only on a showing of prejudice warranting a new trial.
- Jury instructions are reviewed as a whole to determine whether they fairly and correctly state the law; a refusal to give requested language is not error if the substance is adequately covered or not legally required.
- Sufficiency review requires viewing evidence in the light most favorable to the verdict and deferring to the jury’s credibility determinations.
- When a juvenile disposition includes adult-criminal sentencing consequences, the adult-sentence component must satisfy constitutional safeguards associated with criminal punishment, including Sixth Amendment jury-trial requirements as reflected in Apprendi/Blakely line doctrine.
- A constitutionally appropriate remedy may be to vacate the stayed adult sentence while preserving the juvenile adjudication and juvenile disposition.

## Conclusion

The court upheld T.C.J.’s EJJ adjudication and third-degree assault delinquency finding based on sufficient evidence and no reversible trial error, but removed the stayed adult sentence because the adult-punishment component, as imposed in this posture, did not comport with constitutional sentencing protections.


In re Welfare of T.C.J., 689 N.W.2d 787 (Minn. Ct. App. 2004)