16 Year Old Charged With Murder Has No Constitutional Right to Juvenile Court

State v. Angilau, 2011 UT 3 (Utah Supreme Court, January 7, 2011).

Angilau was charged with murder in the district court and moved to have the case heard by the juvenile court.  The motion was denied and Defendant appealed.

The question before the court is the constitutionality of the automatic wavier statute that 16 year olds charged with murder to district court.  The Supreme Court found there is no fundamental right to have a matter tried in juvenile court (since the juvenile court is one of legislative creation, they are permitted to limit its jurisdiction).  Therefore, under a substantive due process test the statute must only have a legitimate state interest.  Being that the goal is to be able to adequately protect the public from murderers, the State may need more time to rehabilitate than the Juvenile Court jurisdiction would allow (being that the maximum sentence in the juvenile court would be 2 years).  Further, the statute does not violate the uniform operation of laws provision.  In this case, there is a classification (16 year olds who are accused with murder); there is a chance that similarly situated individuals will be treated differently (juveniles close to the borders of their 16^th birthday may be treated differently depending on when the alleged crime occurs); However, the legislature has reasonable objectives that warrant the disparate treatment.  Because of the legislative goals, the statute does not violate the uniform operation of laws provision.  Lastly, the statute does not reduce his right to notice and hearing so it is not procedurally unconstitutional.  Affirmed on all grounds.

Full Decision available at http://www.utcourts.gov/opinions/supopin/Angilau010711.pdf