Cameron Tibbs v. State of Indiana, 86 N.E.3d 401

On Dec. 13, 2015, 17‑year‑old Cameron Tibbs shot and killed David Bowman after Bowman accused a car passenger of taking cash and threatened to kill her while reaching toward his pocket. Tibbs was in the car and fired one fatal shot.
Tibbs was charged in adult court with murder, Level 6 felony obstruction of justice, and misdemeanors including carrying a handgun without a license; the dangerous-possession count was later dismissed.
At trial Tibbs asserted self‑defense; the jury acquitted him of murder but convicted him of Level 6 obstruction and Class A misdemeanor carrying a handgun without a license.
After the verdict but before sentencing, Tibbs (now over 18) moved under Ind. Code § 31-30-1-4(c) for the court to withhold judgment and transfer the remaining convictions to juvenile court (a “reverse transfer”).
At the transfer hearing Tibbs presented testimony about juvenile development and family support; the State filed a memorandum attaching charging papers from separate Jackson County adult charges that included a weapon allegation. The trial court orally denied transfer, citing Tibbs’s alleged violations and the Jackson County arrest.
Tibbs appealed, arguing the trial court was required to enter written findings explaining the denial of his reverse-transfer motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court was required to enter written findings when denying motion to withhold judgment and transfer to juvenile court under Ind. Code § 31-30-1-4(c)	State: no statutory or common‑law requirement for written findings; oral explanation and record suffice	Tibbs: statute and due process require detailed findings; sentencing‑statement precedent (Anglemyer) supports requiring findings	Court held trial court was not required to enter written findings and did not abuse its discretion in denying transfer

Tongate v. State, 954 N.E.2d 494 (Ind. Ct. App. 2011) (interpretation of “may” as permissive and conferring discretion)
Lyles v. State, 834 N.E.2d 1035 (Ind. Ct. App. 2005) (discretionary trial-court rulings reviewed for abuse of discretion)
Heaton v. State, 984 N.E.2d 614 (Ind. 2013) (abuse-of-discretion standard defined)
Mitchell v. State, 813 N.E.2d 422 (Ind. Ct. App. 2004) (court will not read requirements into clear statutes)
Lucas v. McDonald, 954 N.E.2d 996 (Ind. Ct. App. 2011) (statutory requirements for findings are enforced when expressed)
Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (sentencing statement requirement and its purposes)
Willsey v. State, 698 N.E.2d 784 (Ind. 1998) (no general obligation to enter findings for criminal rulings)
Miller v. State, 72 N.E.3d 502 (Ind. Ct. App. 2017) (no findings required to support bench‑trial conviction)