In re E.J.D., 301 Kan. 790

E.J.D., a juvenile, faced extended-jurisdiction prosecution under K.S.A. 2014 Supp. 38-2347 with a stayed adult sentence in case 2008-JV-000278.
He later faced allegations of misconduct in a juvenile facility leading to a motion to revoke the stay and impose the adult sentence.
The district court found a new offense sufficient to trigger revocation under K.S.A. 2014 Supp. 38-2364(b) and stayed the adult sentence was revoked.
E.J.D. sought a downward departure before the adult sentence was pronounced and later challenged whether such departure could occur after revocation.
The Court of Appeals affirmed; this court affirmed the district court and Court of Appeals on the revocation and departure issues.
The statutory framework for extended jurisdiction under the juvenile code governs these revocation and modification questions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the extended-jurisdiction scheme allows revocation and imposition of the previously ordered adult sentence.	E.J.D. argues for departure/modification under the juvenile provisions.	State contends the statute requires revocation and imposition of the adult sentence and precludes other modifications.	Yes; revocation and imposition must follow the statute.
Whether K.S.A. 2014 Supp. 38-2364(b) permits revocation based on offenses rather than convictions.	E.J.D. contends no new offense proven beyond reasonable doubt.	State relies on new-offense concept supporting revocation.	Yes; offense-based revocation is authorized.
Whether the Court can downwardly depart from the adult sentence after revocation.	E.J.D. sought downward departure before pronouncement of the adult sentence.	Statute does not allow post-revocation downward durational departure; departure authority is limited.	No; downward departure after revocation is not authorized.
What standard of review applies to the district court's findings under the statute?	N/A	Statutory findings judged by substantial competent evidence.	Substantial competent evidence standard applies.

State v. Williams, 299 Kan. 911 (2014) (statutory interpretation standard (unlimited/de novo) and review principles cited in this context)
State v. Kingsley, 299 Kan. 896 (2014) (statutory interpretation and review considerations relevant to appellate review)
State v. Bailey, 292 Kan. 449 (2011) (preponderance standard in probation-like revocation contexts)
In re A.M.M.-H., 300 Kan. 532 (2014) (juvenile-specific precedence for statutory interpretation)