In re Dahl – Minnesota

Nature of the Case

This case involves the courts discretion in deciding whether a juvenile offender should be referred for prosecution as an adult.

Facts

On April 8, 1978 the body of Rick Alan McGuire was found in a remote area with a shotgun wound to the head. A delinquency petition was filed against Dahl (D) for the first degree murder of McGuire.

Dahl admitted to the killing and was 17 at the time of the murder. Dahl’s parents described him as respectful and obedient. Dahl had never been in serious trouble with the law prior to the murder and had maintained a B average in high school while holding a part time job and participating in athletics.

The trial court observed that Dahl was not a typical delinquent and that he had no prior history that could have predicted this outcome. Dahl was then referred for adult prosecution because it was determined that the juvenile court could not successfully treat him in the time remaining before its jurisdiction would expire, and because of the serious nature of the crime and Dahl’s alleged threat to public safety. Dahl appealed the referral for adult prosecution.

Issue

In the state of Minnesota, may a juvenile offender be referred for adult prosecution merely based on the severity of the crime and the fact that there would be a lack of treatment options for the offender in the juvenile system?

Holding and Rule of Law

No. In the state of Minnesota, a juvenile offender may not be referred for adult prosecution merely based on the severity of the crime and the fact that there would be a lack of treatment options for the offender in the juvenile system.

We look for guidance in the statute in deciding when a juvenile should be referred for adult prosecution. In this case however the statute offers little guidance to govern our decision. The legislature never singled out certain crimes that would automatically require a referral to adult courts.

Looking to the record, no psychological tests were performed on Dahl to determine whether he could receive effective treatment or to determine whether he was a threat to public safety. The record must explain more clearly how Dahl is a threat to public safety, otherwise he is being referred based on the crime alone, which is not what the legislature intended. The record fails to show that Dahl is not suitable to treatment or that he is a threat to public safety. The lower court simply placed him into adult court based on his offense.

Disposition

The referral to adult court is vacated and the matter is remanded for further proceedings.