Friday, November 15, 2013

In re Dahl case brief

In re Dahl case brief summary
278 N.W.2d 316 (1979)

Defendant, a juvenile, was granted permission to appeal an order from the District Court, Beltrami County (Minnesota), which affirmed the juvenile court's referral of defendant for adult prosecution.

Defendant was charged with delinquency for first-degree murder. Defendant was 17 years old at the time of the alleged offense and 18 years old at the time the delinquency petition was filed. The State requested that the juvenile court enter an order referring defendant for prosecution as an adult pursuant to Minn. Stat. § 260.125.

The juvenile court referred defendant for prosecution as an adult on both non-amenability to treatment and public safety grounds. Defendant appealed the juvenile court's decision to the district court. The district court affirmed the decision of the juvenile court.


  • On further review, the supreme court vacated the reference order. 
  • The court held that the juvenile court's finding that defendant could not be successfully treated within the juvenile court's jurisdiction was not reasonably supported by the evidence. 
  • There was no supporting psychological data or history of misconduct. 
  • Defendant's age was not to be a substantial factor in determining whether reference was appropriate.

The court vacated the reference order and remanded the case for further proceedings.

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