W.J.S. v. State, 495 S.W.3d 649

In Aug. 2012 the State filed a petition charging W.J.S. (a minor) with rape; in Oct. 2012 he pled true to amended charge of sexual assault in the 4th degree and was adjudicated delinquent.
He was placed on probation, ordered to residential treatment, and ordered to complete a Community Notification Risk Assessment; a follow-up hearing was to be set if the assessment warranted review.
In July 2015 (age 14) a UAMS social worker completed a sex-offender risk assessment recommending registration; the State filed a motion to require juvenile registration.
At the registration hearing the juvenile moved to dismiss, arguing the State lacked statutory authority to file the motion; the trial court denied the motion and ordered registration.
The trial court’s written order recited the statutory factors but did not make specific written findings on each factor; the juvenile appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State was authorized to file the registration motion under Ark. Code § 9-27-356	Juvenile: Dismiss because § 9-27-356(d) authorizes a prosecutor’s motion only when juvenile is adjudicated for subsection (a) offenses	State: For juveniles adjudicated under subsection (b), the court may order registration upon assessment recommendation and a hearing per § 9-27-356(b)(2)	Court: Denied juvenile’s argument; subsection (b)(2) authorizes a hearing and registration based on assessment recommendation, so dismissal not required
Whether the trial court’s order satisfied the statute’s requirement to make written findings on each factor and whether the registration finding was supportable	Juvenile: Trial court clearly erred and failed to make specific written findings on all factors in § 9-27-356(e)	State: Order listed factors and relied on assessment and testimony	Court: Remanded — listing factors without individualized written findings is inadequate; court must enter an order with findings on all statutory factors

State v. V.H., 429 S.W.3d 243 (Ark. 2013) (rules for statutory interpretation and de novo review of statute application)