People Ex Rel. J.L.
2011 S.D. LEXIS 64
S.D.2011Background
- J.L., age 14, engaged in consensual intercourse with his girlfriend, age 12, resulting in pregnancy.
- J.L. was adjudicated delinquent under SDCL 26-8C-2 for a crime that would be statutory rape if an adult.
- The underlying offense was SDCL 22-22-1(1) (statutory rape), which requires that the victim be under age thirteen.
- Girlfriend was under the age of consent; J.L. was over thirteen at the time, creating a one-sided application of the statute.
- J.L. challenges the application as producing an absurd result not intended by the Legislature.
- The majority affirms the delinquency adjudication, stating the statute’s plain terms apply and no absurd result is shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does applying SDCL 22-22-1(1) to these facts yield an absurd result? | J.L. argues the result is absurd given near-equal ages and consensual conduct. | State contends the statute’s plain language controls and there is no absurdity. | No absurd result; statute applied as written |
| Is there ambiguity that would permit a different construction? | Ambiguity exists when literal application leads to an unlikely outcome. | Language is clear; no need to expand beyond clear terms. | No ambiguity requiring reinterpretation |
| Should juveniles be exempt from delinquency due to age differential under the rape statute? | Legislature would not intend punishment via delinquency for near-equal-aged peers. | Legislature chose a uniform standard; no differential treatment here. | Legislation explicitly protects under-thirteen victims; no exemption for this case |
| What are the collateral consequences of application (e.g., sex-offender registration)? | Labeling as a sex offender for life is unduly harsh and rehabilitative goals of juvenile system undermined. | Statutory requirements are established by the Legislature and must be followed. | Court notes consequences but upholds delinquency decision |
Key Cases Cited
- Dakota Plains Agricultural Center, LLC v. Smithey, 772 N.W.2d 170 (S.D. 2009) (absurd result when one statute would render another statute meaningless)
- Schafer v. Shopko Stores, Inc., 741 N.W.2d 758 (S.D. 2007) (rejecting expansive interpretation that creates tortious liability)
- In re S.K., 587 N.W.2d 740 (S.D. 1999) (juvenile proceedings aim to rehabilitate, not punish)
- State v. Davis, 598 N.W.2d 535 (S.D. 1999) (statutes should be given sensible, practical construction)
- In re Z.B., 757 N.W.2d 595 (S.D. 2008) (absurd result discussed where both participants could be treated as victims and perpetrators)