State of Louisiana in the Interest of J.P. ., 280 So.3d 245

April 24–25, 2018: Report of simple burglary of a silver Nissan Altima in a Delgado Community College parking lot; police obtained surveillance video.
Detective Nicole Alcala reviewed the video, identified one of the persons as J.P. (based on prior encounters), and obtained an arrest warrant; J.P. was charged in juvenile delinquency court with simple burglary (La. R.S. 14:62(A)).
At trial the State presented only Detective Alcala’s testimony and the surveillance video; Alcala did not testify the vehicle owner denied permission or that anything was taken, nor did she interview J.P. on intent.
The surveillance footage shows J.P. approach the Nissan, open the driver’s door, enter briefly, exit, close the door, and walk away; it does not show actions inside the vehicle or any verbal exchange with the owner.
The juvenile court adjudicated J.P. delinquent for simple burglary based on Alcala’s identification and the video; the court inferred lack of authorization and intent from those materials.
The Court of Appeal reversed and rendered: it found the evidence insufficient to exclude the reasonable hypothesis that J.P. was authorized to enter the vehicle or lacked intent to commit a theft/felony, and dismissed the petition with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to adjudicate J.P. delinquent of simple burglary (unauthorized entry with intent to commit theft/felony)	Video identification by Detective Alcala and the surveillance footage establish entry and support inferences of lack of permission and criminal intent	Video and testimony do not prove lack of authorization or specific intent; footage shows only brief entry and no taking or furtive acts inside the vehicle	Reversed and rendered: evidence insufficient — reasonable hypotheses of authorization and lack of criminal intent were not excluded; petition dismissed with prejudice

In re Winship, 397 U.S. 358 (1970) (Due process requires proof beyond a reasonable doubt in juvenile adjudications)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence: could any rational trier of fact find guilt beyond a reasonable doubt)
State v. Brown, 115 So.3d 564 (La. App. 4th Cir.) (explains hybrid Jackson/manifest-error sufficiency review in juvenile cases)
State v. Marcello, 385 So.2d 244 (La. 1980) (burglary requires specific intent to commit felony or theft at time of unauthorized entry)
Burks v. United States, 437 U.S. 1 (1978) (reversal for insufficiency requires acquittal; double jeopardy bars retrial)