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State v. B.C.E.T.
Citation: 422 P.3d 772Docket: Case Number: JS-2017-1315
Court: Court of Criminal Appeals of Oklahoma; May 24, 2018; Oklahoma; State Appellate Court
Angela Marsee, the District Attorney, and S. Brooke Gatlin, the Assistant District Attorney, represent the State in the case against B.C.E.T., who was charged as an adult with Felony Murder, Shooting with Intent to Kill, and Burglary, all stemming from incidents occurring on July 20, 2017, when B.C.E.T. was 14 years old. On August 31, 2017, B.C.E.T. filed a motion for certification as a child or, alternatively, as a youthful offender. Judge Jill C. Weedon presided over the preliminary hearing and the motion for reverse certification, ultimately denying juvenile certification but granting youthful offender status. The State of Oklahoma appealed this decision, arguing that B.C.E.T. did not provide sufficient evidence to qualify for youthful offender status. The appeal was assigned to the Accelerated Docket, with oral arguments held on March 29, 2018. The court affirmed the trial court's order, finding no abuse of discretion. Key evidence considered included testimony from three psychological experts who evaluated B.C.E.T., all stating he was amenable to treatment and had a moderate risk of reoffending. However, it was noted that this risk assessment did not account for the behaviors related to the charged offenses. The court emphasized that evaluations should consider a juvenile's complete behavioral history. Despite concerns about the expert testimony, Judge Weedon was found to have appropriately weighed B.C.E.T.'s behaviors and the expert opinions in line with the reverse-certification guidelines. Certification motions require courts to predict future behaviors and necessitate expert testimonies for informed decision-making. The case J.R.L. v. State establishes that statutory criteria for reverse-certification as a youthful offender demand a psychological evaluation, indicating the necessity of such evaluations alongside certification studies. Determining a juvenile's amenability to treatment involves predicting future outcomes, making expert testimony crucial not as a sole determinant but to aid the court's assessment. Experts must provide detailed insights into a youth's mental and medical issues and how specific programs will address them. In this case, the State's criticisms of the expert testimony primarily pertain to the credibility and weight of the evidence, rather than opposing expert input, as no counter-experts were presented. The credibility of witnesses and the evaluation of their testimony fall under the magistrate's discretion. Appellate review focuses on whether the magistrate's decision aligns with legal and factual support, not on reweighing the evidence. The ruling by Judge Weedon, which was based on comprehensive findings, is upheld as it is supported by competent evidence and does not constitute an abuse of discretion. The District Court's order to certify the Appellee as a youthful offender is affirmed. The decision highlights a concurrence from the Vice Presiding Judge, who clarifies that the experts did, in fact, consider the charged offenses in their evaluations, thus reinforcing the trial court's decision.