In the Matter of the Welfare of: F. C. R., Child., A16-424

In 2015, multiple firearms were reported stolen; seven stolen guns were later recovered buried near a trailer park, including a rifle taken from a Minnesota State Trooper vehicle.
A convenience/liquor store was robbed in October 2015 by four armed individuals; the cashier surrendered $1,340.60. Walmart receipt and security footage placed appellant F.C.R. at Walmart hours before the robbery.
Law enforcement determined F.C.R. (born Feb. 14, 1998) provided the firearms, possessed a loaded gun during the robbery, demanded money from the cashier, threatened others with a firearm, and said he would shoot police. He was 17 at the time.
F.C.R. was charged in two juvenile delinquency petitions: first-degree aggravated robbery and second-degree assault with a dangerous weapon; and five counts of receiving stolen property. The state moved to certify him as an adult on both petitions.
Probation recommended EJJ (extended jurisdiction juvenile) status on both petitions; family witnesses supported rehabilitation. The district court presumed the petition facts true for certification purposes and certified F.C.R. as an adult on both petitions.
This appeal challenges the district court’s refusal to grant EJJ status; the appellate court affirms certification to adult court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellant rebutted the statutory presumption favoring adult certification for the aggravated-robbery charge	F.C.R. argued public safety favored juvenile EJJ treatment and he should rebut certification presumption	State argued statutory presumption applied because F.C.R. was 17 and the charge involved a firearm/presumptive prison exposure	Court held appellant failed to rebut presumption by clear and convincing evidence; certification proper
Whether receiving-stolen-property petition should be retained in juvenile court absent presumption	F.C.R. argued this nonviolent charge should remain juvenile, especially if not for simultaneous robbery certification	State argued public safety factors (seriousness, culpability, program inadequacy) supported adult certification even without presumption	Court held state proved by clear and convincing evidence that public safety favored adult certification; certification proper

In re Welfare of J.H., 844 N.W.2d 28 (Minn. 2014) (standard of review and need to identify statutory basis when weighing certification factors)
In re Welfare of N.J.S., 753 N.W.2d 704 (Minn. 2008) (public-safety finding for certification reviewed for clear error)
In re Welfare of H.S.H., 609 N.W.2d 259 (Minn. App. 2000) (adult certification may be appropriate for serious nonviolent crimes)