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State v. J.L.M.
Citation: 996 So. 2d 740Docket: No. 2007-CA-01160-SCT
Court: Mississippi Supreme Court; December 3, 2008; Mississippi; State Supreme Court
On July 31, 2005, J.L.M., a 16-year-old, was involved in an incident with his 8-year-old cousin, B.S., leading to two sexual battery charges against J.L.M. Initially, the Youth Court of Pearl River County dismissed the case for lack of jurisdiction, after which J.L.M. was indicted in Circuit Court. He subsequently filed a Motion to Refer Case to Youth Court, which the State opposed. An evidentiary hearing was held on June 8, 2007, where testimony from various witnesses supported J.L.M.'s position. The Circuit Court judge decided to transfer the case to Youth Court, deeming it in the best interest of justice and J.L.M. The Youth Court accepted the transfer, and J.L.M. pleaded no contest to the charges on June 12, 2007, receiving a fine and a psychological evaluation as part of his disposition. The State appealed the Circuit Court's decision to refer the case to Youth Court, arguing that double jeopardy protections under the Fifth Amendment did not apply to youth court proceedings and that the Circuit Court abused its discretion. However, the court affirmed the decision, noting that the Fifth Amendment does extend to youth court proceedings, as established by the U.S. Supreme Court in Breed v. Jones. It was concluded that even if the transfer had been appealable, the State forfeited that right once the Youth Court issued a final judgment. Further proceedings after an adjudicatory hearing would constitute double jeopardy, referencing Walls v. State. The State argues that the Fifth Amendment's double jeopardy protection applies only to criminal proceedings, asserting that juvenile court actions are civil in nature per Mississippi law, thus making the double jeopardy claim irrelevant. However, this argument is rejected as courts must look beyond the "civil" label in juvenile cases. The youth court's final judgment bars the State's appeal based on the Fifth Amendment, rendering its other arguments moot. The opinion acknowledges the uncomfortable result of allowing a criminal defendant, especially a child’s assailant, to face minimal punishment, yet emphasizes that adherence to constitutional protections necessitates this outcome. The court highlights its role in upholding constitutional rights, regardless of the unpleasantness of certain decisions. Ultimately, the court affirms the decision of the Pearl River County Circuit Court. The justices express varying levels of concurrence and dissent, with specific justices noting their agreement with certain aspects of the ruling while others dissent without additional commentary.