## Facts

- Minor M.J.W. was accused of burning and destroying school property and was proceeded against in juvenile court as a delinquent child based on conduct amounting to criminal trespass.
- The State’s evidence included eyewitness testimony that M.J.W. struck and threw a match into a school restroom trash can containing dry paper, which then burst into flame.
- M.J.W. testified the match was used to light a cigarette, that it was extinguished before being tossed into the trash, and that he did not intend to start a fire.
- School officials testified the resulting damage to school property was less than $25.
- After hearing conflicting testimony, the juvenile court judge found the required criminal intent, adjudicated M.J.W. delinquent, and placed him on probation.
- As a condition of probation, the court ordered M.J.W. to perform 100 hours of unpaid work for the Parks and Recreation Department.
- M.J.W. appealed, challenging (1) the sufficiency of the evidence of intent and (2) the legality of the community-service condition as the equivalent of an unlawful fine and as unconstitutional involuntary servitude.

## Issues

1. Whether the evidence was sufficient to support the juvenile court’s finding that M.J.W. acted with the intent required to commit criminal trespass by damaging school property.
2. Whether a probation condition requiring a juvenile adjudicated delinquent to complete 100 hours of unpaid community service constitutes involuntary servitude or an impermissible fine.

## Decision

- The Court of Appeals of Georgia held that sufficient evidence supported the juvenile court’s finding of criminal intent and the resulting delinquency adjudication.
- The court held that requiring 100 hours of unpaid work for a public agency as a condition of juvenile probation did not constitute involuntary servitude and was not the equivalent of a prohibited monetary fine.
- The juvenile court’s judgment, including the probation condition, was affirmed.

## Legal Principles

- Criminal intent is ordinarily a question for the factfinder and may be determined from the defendant’s words, conduct, demeanor, motive, and surrounding circumstances.
- When evidence is in direct conflict, the trial-level factfinder (including a juvenile court judge sitting as factfinder) may credit one version of events over another, and an appellate court will not reweigh credibility where evidence supports the finding.
- A person may be found to intend the natural and probable consequences of knowingly performed acts, allowing intent to be inferred from the circumstances.
- Juvenile probation conditions may include non-monetary obligations designed to correct behavior; community service can be a permissible condition within the court’s dispositional authority.
- Limited, court-ordered community service tied to a lawful probationary disposition does not amount to unconstitutional involuntary servitude merely because it requires unpaid labor.

## Conclusion

M.J.W. v. State upheld a juvenile court’s delinquency adjudication arising from a fire that damaged school property, ruling that the juvenile judge could infer intent from the evidence despite conflicting testimony and that a 100-hour community-service requirement as a probation condition was lawful, not a forbidden fine, and not involuntary servitude.


M.J.W. v. State, 210 S.E.2d 842 (1974)