United States v. Woods, 827 F.3d 712

In 2010, when he was 15, Leslie Woods III allegedly participated in two armed robberies in Cahokia, Illinois; one victim was shot during the first robbery and the clerk was shot multiple times in the second, suffering permanent injuries.
The government filed a juvenile information in May 2015 charging Woods with multiple federal offenses and moved to transfer him for adult prosecution under the Juvenile Justice and Delinquency Act ("Juvenile Act").
At filing Woods was 20; by the time of the transfer hearing his trial had not occurred and he had turned 21. The Attorney General certified the required jurisdictional prerequisites for transfer.
The district court conducted a transfer hearing, considered the six statutorily listed factors in 18 U.S.C. § 5032, and received surveillance video, an FBI affidavit, testimony about Woods’s gang involvement, and testimony from his juvenile-probation officer describing extensive juvenile contacts and failed rehabilitation efforts.
The district court found factors (age/social background, nature of the offense, prior delinquency, response to treatment, and availability of programs) weighed for transfer; intellectual/psychological maturity was neutral; the court ordered transfer to adult prosecution.
The court unsealed Woods’s name after affirming transfer because juveniles prosecuted as adults are no longer entitled to the anonymity preserved by 18 U.S.C. § 5038.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Juvenile Act still applies when a defendant charged while under 21 turns 21 before trial	Govt: Juvenile Act jurisdiction is fixed at the time of filing; continuing juvenile jurisdiction is permitted	Woods: (conceded in supplemental brief) also agreed Juvenile Act applies — main dispute was transfer appropriateness	The court followed other circuits and held the Juvenile Act remains applicable if the defendant was under 21 at filing; it reviewed transfer under that statute
Whether the district court abused its discretion in transferring Woods to adult prosecution under 18 U.S.C. § 5032	Woods: The court misapplied burdens, failed to account for state’s failure to place him in recommended out-of-home treatment, and should have given more weight to his youth at time of offenses	Govt: District court properly weighed the six statutory factors, gave appropriate consideration to evidence of gang involvement, violent offenses, and failed rehabilitation	The court held there was no abuse of discretion; the district court thoroughly analyzed each § 5032 factor and reasonably concluded transfer was in the interest of justice

United States v. Jarrett, 133 F.3d 519 (7th Cir.) (describing transfer criteria and standard of review under the Juvenile Act)
United States v. Ramirez, 297 F.3d 185 (2d Cir. 2002) (juvenile jurisdiction determined at initiation; continuing jurisdiction when defendant turns 21)
United States v. Smith, 851 F.2d 706 (4th Cir. 1988) (permits retention of juvenile jurisdiction after defendant attains 21)
United States v. Martin, 788 F.2d 696 (11th Cir. 1986) (same principle on timing of juvenile jurisdiction)
United States v. Doe, 631 F.2d 110 (9th Cir. 1980) (statutory interpretation allowing juvenile proceedings to continue if defendant turns 21 during proceedings)