## Facts

- Jonas Dixon was 15 years old and lived with his mother, who had mental-health problems.
- Dixon observed that adult men regularly came to the home to have sex with his mother, and he believed they were taking advantage of her condition.
- One night, an intoxicated man came to the home and had sex with Dixon’s mother while Dixon was present in the house.
- After hearing them, Dixon retrieved a 12-gauge shotgun, intending to scare the man and make him leave.
- Dixon confronted the man and ordered him to leave while holding the shotgun.
- The man ran toward Dixon and grabbed the gun, and the two struggled over it.
- Dixon believed that if the man got control of the gun, the man would shoot him.
- During the struggle, Dixon disengaged the safety and fired at close range, killing the man with a shot to the chest.
- The State charged Dixon in criminal (adult) court with second-degree murder.
- Dixon moved to transfer the case to juvenile court; the trial court denied the motion.
- Dixon took an interlocutory appeal to the Vermont Supreme Court challenging the denial of transfer.

## Issues

1. Whether the trial court applied the proper statutory standard and acted within its discretion when it denied Dixon’s motion to transfer the second-degree murder prosecution to juvenile court.

## Decision

- The Vermont Supreme Court affirmed the trial court’s order denying transfer to juvenile court.
- The Court held that the trial court considered the required statutory factors and did not abuse its discretion by concluding the case should remain in adult criminal court.

## Legal Principles

- A transfer (or “reverse waiver”) decision requires the trial court to consider the statutory factors governing whether a juvenile charged in criminal court should instead be handled in juvenile court.
- The trial court must base its ruling on the statutory criteria and the evidentiary record, and it must explain its reasoning sufficiently to permit appellate review.
- The seriousness and circumstances of a charged homicide may be given substantial weight in the transfer analysis, even when the juvenile offers evidence of difficult family circumstances and potential for rehabilitation.
- On appeal, the Vermont Supreme Court reviews a transfer ruling for legal error and abuse of discretion; it does not reweigh competing evidence if the trial court applied the correct framework and made supported findings.

## Conclusion

The Vermont Supreme Court affirmed the denial of Dixon’s motion to transfer because the trial court applied the statutory transfer factors and reasonably concluded that the seriousness and circumstances of the alleged second-degree murder, along with public-safety concerns and the limits of juvenile-court jurisdiction, justified keeping the case in adult criminal court despite Dixon’s youth and mitigating background evidence.


State v. Dixon, 967 A.2d 1114 (2008)