Federal offense doesn’t count for juvenile’s adjudication

The Missouri Court of Appeals Western District ruled Sept. 5 that a judge lacked jurisdiction over a juvenile offender alleged to have violated a federal gun law.

Although the teenager in the case is also alleged to have committed other offenses that could keep him in the juvenile system, the ruling suggests that “Missouri cannot prosecute a child solely for an alleged violation of federal law,” said Jeffrey C. Esparza, a public defender who appealed on behalf of the juvenile, referred to as D.C.

In 2020, Buchanan County juvenile authorities alleged D.C., then 16, was caught with a handgun. He waived his right to counsel and admitted the allegations, prompting Judge Patrick K. Robb to place him on supervised probation.

In 2022, the juvenile office alleged that D.C. had committed additional offenses, including stealing and drug use. The judge placed the teen in the custody of the Division of Youth Services.

D.C., now represented by an attorney, appealed, arguing that the juvenile court never had jurisdiction over him because the original charge was based on a federal law that forbids those under 18 from possessing a handgun in most circumstances.

Judge Alok Ahuja, writing for the Western District, agreed. State courts cannot enforce federal law, so D.C.’s original adjudication was invalid from the start, he wrote. Judges Karen King Mitchell and Edward R. Ardini Jr. concurred.

Ahuja cited a 1982 ruling from Washington and a 1997 case from Minnesota, which similarly held that juvenile courts lacked jurisdiction over federal offenses. In contrast, the California Supreme Court held in 2009 that its courts did have such jurisdiction, but only because California law specifically allowed juveniles to be made wards of the court for violations of the laws of the United States.

Missouri’s juvenile code, in contrast, specifically applies to “any child who is alleged to have violated a state law or municipal ordinance.”

“Under these decisions, we conclude that Missouri state courts lack subject matter jurisdiction to adjudicate juveniles as delinquent based on their violation of federal criminal laws,” Ahuja wrote.

The court remanded D.C.’s case for the judge to make a new ruling based solely on his state-law offenses.

The case is In re: The Matter Of: D.H.C v. Juvenile officer, WD85324.