A district court has wide latitude when certifying a juvenile for adult prosecution, and its findings will be affirmed unless clearly erroneous so as to constitute an abuse of discretion. In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn.App. 2007), review denied (Minn. Oct. 24, 2007).
In each of those cases, the juvenile court determined that the seriousness of the alleged offense favored certification but that the prior-record-of-delinquency factor favored an EJJ proceeding. See J.H., 844 N.W.2d at 36; In re Welfare of S.J.T., 736 N.W.2d 341, 353-54 (Minn. App. 2007), review denied (Minn. Oct. 24, 2007).
Minn.Stat. § 260B.125, subd. 4(2). “For purposes of certification, the juvenile is presumed guilty of the alleged offenses.” In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn.App.2007), review denied (Minn. Oct. 24, 2007).
Minn. Stat. § 260B.125, subd. 4(2). "For purposes of certification, the juvenile is presumed guilty of the alleged offenses." In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn. App. 2007), review denied (Minn. Oct. 24, 2007).
"Thus, in presumptive-certification proceedings, the state bears the burden of showing that (1) the juvenile was 16 or 17 years old, and (2) the alleged offense carries a presumptive prison sentence." In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn. App. 2007), review denied (Minn. Oct. 24, 2007).
A district court abuses its discretion if its disposition is arbitrary or based on clearly erroneous factual findings. See In re Welfare of J.A.J., 545 N.W.2d 412, 414 (Minn. App. 1996); see also In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn. App. 2007), review denied (Minn. Oct. 24, 2007).
In In re Welfare of S.J.T., this court stated that "[i]nsufficient time for rehabilitation under the juvenile system is an appropriate consideration when determining whether to certify a juvenile." 736 N.W.2d 341, 354 (Minn.App. 2007), rev. denied (Minn. Oct. 24, 2007). Here, appellant was 17 years old at the time of the offense and was alleged to have committed a crime for which there is a presumptive sentence.
In re Welfare of J.H., 844 N.W.2d 28, 34 (Minn. 2014); see In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn. App. 2007) ("A district court has considerable latitude in deciding whether to certify, and this court will not upset its decision unless its findings are clearly erroneous so as to constitute an abuse of discretion." (quotation omitted)), review denied (Minn.
"A district court has considerable latitude in deciding whether to certify, and this court will not upset its decision unless its findings are clearly erroneous so as to constitute an abuse of discretion." In re Welfare of S.J.T., 736 N.W.2d 341, 346 (Minn. App. 2007) (quotation omitted), review denied (Minn. Oct. 24, 2007).
Even if we assume error on factors 5 and 6, we cannot grant relief unless G.M.D. also shows prejudice. See In re Welfare of S.J.T., 736 N.W.2d 341, 352 (Minn.App. 2007) (requiring juvenile appellant to show that district court's error prejudiced its certification decision), rev. denied (Minn. Oct. 24, 2007). We conclude he cannot.