State ex rel. S.J., 129 So. 3d 676

S.J. appeals a juvenile court adjudication finding delinquency for unauthorized use of a movable (La. R.S. 14:68).
Movable was a vehicle owned by Reginald Fortenberry; Fortenberry testified he did not give S.J. permission to operate the vehicle and that it sustained substantial damage.
Priantae Green, Fortenberry’s daughter, testified she had not given S.J. permission to drive her father’s truck and that S.J. drove away after she offered a ride.
The record includes a stipulation that, if called, an officer would say the police report notes Green’s statement that she left the keys in the vehicle.
At adjudication, the court relied on Fortenberry and Green’s testimony to find S.J. lacked permission and acted with intent to use the vehicle unlawfully.
The disposition placed S.J. on probation after a suspended commitment; S.J. timely appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence on intent	S.J. argues lack of intent to joyride.	State contends intent can be inferred from circumstances.	Evidence supports inferred intent; sufficient beyond reasonable doubt.
Preservation of error on cross-examination	S.J. contends cross-exam of Fortenberry limited to bias.	State argues ruling was relevant; defense failed to preserve.	Issue not preserved due to no offer of proof; review denied.

State ex rel. C.B., 09-1114, 28 So.3d 525 (La. App. 4 Cir. 2009) (no less stringent standard than criminal cases for delinquency burden)
State in the Interest of A.G., 630 So.2d 909 (La. App. 4 Cir. 1993) (heightened standard for burden in juvenile matters)
State ex rel. W.B., 11 So.3d 60 (La. App. 4 Cir. 2009) (great deference to trial court findings)
Jackson v. Virginia, 443 U.S. 307 (1989) (sufficiency standard: any rational trier of fact could find guilt beyond reasonable doubt)
State v. Williamson, 81 So.3d 156 (La. App. 5 Cir. 2011) (intent may be inferred from circumstances)