In re the Welfare of J.H., 2014 Minn. LEXIS 107

J.H. was 17 at the time of the alleged offenses and faced a delinquency petition alleging first-degree criminal sexual conduct, conspiracy to commit first-degree criminal sexual conduct, kidnapping, and committing a crime for the benefit of a gang; charged as both principal and accomplice.
G.K., age 14, reported rape by TB22 gang members at parties; the crime involved forcible extraction from a car, hallway assault, and rape in a house bedroom with several gang members present, including J.H.
The juvenile court found that J.H. did not rebut the presumption of certification and certified him for adult prosecution.
The court of appeals reversed, holding the court must expressly weigh the seriousness of the offense and prior delinquency separately from other public-safety factors and show how those factors affected the decision.
The Supreme Court held that § 260B.125(4) does not require express separate weighing or delineation, only greater weight to those two factors and identification of the statutory basis; the juvenile court’s order satisfied the statute.
The court ultimately affirmed certification, finding substantial record support for the court’s weighing and for its conclusions on all public-safety factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 260B.125(4) requires express separate weighing of seriousness and prior delinquency.	J.H. (State) relied on plain text; no need for express discrete weighing.	J.H. (State) urged the need for explicit delineation of impact of those two factors.	No; court must give greater weight to those factors but need not expressly weigh/delineate separately.
Whether the juvenile court adequately weighed all six public-safety factors.	Court properly considered the six factors and found four others supported certification.	Appeals argued several findings were clearly erroneous and not properly weighed.	Court’s findings were supported; certification affirmed.

In re Welfare of D.F.B., 433 N.W.2d 79 (Minn. 1988) (abuse of discretion standard in certification context; weighing factors not rigidly formulaic)
In re Welfare of R.J.E., 642 N.W.2d 708 (Minn. 2002) (de novo legal questions; clearly erroneous standard for factual findings)
In re Welfare of N.J.S., 753 N.W.2d 704 (Minn. 2008) (public-safety factors and presumption considerations in juvenile proceedings)
In re Welfare of J.J.P., 831 N.W.2d 260 (Minn. 2013) (statutory interpretation and whole-text approach in juvenile statutes)
Vang v. State, 788 N.W.2d 111 (Minn. 2010) (noting that explicit findings per factor are not always required; must identify statutory basis)