In the Interest of: J.A.T. v. Jackson County Juvenile Office

CourtMissouri Court of Appeals
DecidedJuly 20, 2021
DocketWD83968
StatusPublished

This text of In the Interest of: J.A.T. v. Jackson County Juvenile Office (In the Interest of: J.A.T. v. Jackson County Juvenile Office) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest of: J.A.T. v. Jackson County Juvenile Office, (Mo. Ct. App. 2021).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT IN THE INTEREST OF J.A.T., ) Appellant, ) ) v. ) WD83968 ) JACKSON COUNTY JUVENILE ) FILED: July 20, 2021 OFFICE, ) Respondent. ) Appeal from the Circuit Court of Jackson County The Honorable Jalilah Otto, Judge Before Division Two: Mark D. Pfeiffer, P.J., and Alok Ahuja and Karen King Mitchell, JJ. J.A.T. is a juvenile. The Circuit Court of Jackson County entered a judgment

finding that he committed acts which would constitute the felonies of first-degree

assault and armed criminal action if he were an adult. The court committed J.A.T.

to the custody of the Division of Youth Services.

Due to the risk of disease transmission associated with the COVID-19

pandemic, the circuit court refused to transport J.A.T. from the detention facility

where he was in custody to the court for his adjudication hearing, and J.A.T.

accordingly participated in the hearing by videoconference (although all other trial

participants were physically present in the courtroom).

J.A.T. appeals. He argues that the evidence was insufficient to find that he

committed acts constituting first-degree assault and armed criminal action,

personally or as an accomplice. He also argues that the circuit court denied his constitutional rights to due process and to confront adverse witnesses when it

required him to participate in the adjudication hearing by videoconference.

We reject J.A.T.’s sufficiency-of-the-evidence claim. Based on the reasoning

of our recent opinion in In re C.A.R.A., No. WD83967 (July 6, 2021), we conclude

that J.A.T.’s right to confront adverse witnesses was violated when the court

refused to permit him to appear at his adjudication hearing in person, without any

specific finding that his exclusion from the hearing was necessary or justified by

exceptional circumstances. Based on this conclusion, we would normally reverse

the circuit court’s judgment and remand for further proceedings. Like in C.A.R.A.,

however, we instead order that the case be transferred to the Missouri Supreme

Court for final disposition pursuant to Rule 83.02, given the general interest and

importance of the Confrontation Clause issues which J.A.T. raises.

Factual Background On January 17, 2020, the Juvenile Officer filed a petition in the Circuit Court

of Jackson County, alleging that fourteen-year-old J.A.T. had committed acts which

would constitute the felonies of assault in the first degree and armed criminal

action if he were an adult. The Juvenile Officer alleged that, on or about January 7,

2020, J.A.T. knowingly caused serious physical injury to Dalvon Stiner by shooting

Stiner multiple times. The Juvenile Officer alleged that J.A.T. committed the

offenses personally, or with an accomplice for whom J.A.T. would be criminally

responsible if tried as an adult.

Prior to his adjudication hearing, J.A.T. filed a written objection to being

required to participate in the hearing solely by means of videoconferencing

technology, and not being permitted to attend the hearing in person. J.A.T. argued

that denying him the right to personally attend the hearing would violate his rights

under the United States and Missouri Constitutions, and under Missouri statutes and Supreme Court rules. The Juvenile Officer filed a response, arguing that

2 restricting J.A.T. to participation by videoconference was legally justified and

appropriate in light of the ongoing COVID-19 pandemic.

The adjudication hearing was held on July 7, 2020. The circuit judge, J.A.T.’s

attorney, the attorney for the Juvenile Officer, a Deputy Juvenile Officer, a Victim

Services representative, J.A.T.’s parents, and both of the fact witnesses appeared at

the adjudication hearing in person. Only J.A.T. appeared by videoconference.

At the outset of the hearing, J.A.T. renewed his objection that he should be

permitted to attend the hearing in person. The court denied J.A.T.’s request to be

physically present. Addressing J.A.T.’s counsel, the court explained:

I think I've said this before or not in this case, but I have in other cases. In the times of the pandemic, of the coronavirus and COVID-19, we've had to make a number of significant adjustments to how we do things in court. One of them is utilizing the Webex [two-way videoconferencing] technology, which the Supreme Court has explicitly given us permission to do so. That coupled with the fact that there have been numerous detention facilities who have had difficulty . . . keeping COVID-19 out of their facilities. Our facility has done a great job of doing that. We want to keep doing that. One of the policies being put in place by the detention center of the Family Court is that the juveniles will not be transported to and from court to limit the exposure to germs of that particular juvenile as well as additional juveniles in detention. The Court believes that's reasonable for them to make such a policy. It's reasonable for the Court to follow it. Furthermore, following the Webex procedure as outlined by the Supreme Court, I don't believe, violates his due process rights in any way. For that reason, I will deny your request to have him here in person. An intern for J.A.T.’s attorney was present in the detention facility with J.A.T.

throughout the hearing. Moreover, J.A.T.’s attorney relocated to the detention

center to be with J.A.T. during a recess in the adjudication hearing; counsel

presented his closing argument to the court from the detention center, in J.A.T.’s physical presence.

3 At the adjudication hearing, the victim Dalvon Stiner testified that at the

time of the incident he was living in his car and selling marijuana to support

himself. On January 7, 2020, Stiner was contacted on Snapchat by an individual

with the username RHNJonas, who requested to purchase marijuana from Stiner.

Stiner agreed to meet RHNJonas at an apartment complex in Grandview.

It was dark when Stiner arrived at the agreed location. Stiner remained in

his vehicle. Two people approached him with money for the drug purchase, $60

each. Stiner was not expecting two people, and became suspicious that they might

try to rob him. After the two individuals gave Stiner their money, however, he let

them into his car, with one individual sitting in the front passenger seat and the

other in the back. Stiner testified the individual in the front seat was a light-

skinned African-American male, wearing dark clothing, and with a “little bit long

hair,” an “afro.”

The purchasers asked Stiner to divide the marijuana into two separate bags

for them. As Stiner began to divide the marijuana, he recalled “just being, like

rushed. Like, somebody reached up trying to grab stuff. And then I just remember

hearing the shots and blacking out.” Stiner testified that it appeared that the front-

seat passenger was trying to grab the bags of marijuana that were in the console between the front seats. Stiner responded by trying to pull the bags back, when he

was shot and blacked out. Stiner was shot six times. When Stiner woke up, there

was “blood everywhere.” He first called a friend, and then the police. Stiner was

taken to the hospital, where he required surgery.

Stiner testified he did not see who shot him, nor did he see either person with

a gun. Although Stiner was armed that night, and had his gun nearby at the time

of the assault, he did not shoot or even pull out his weapon, as “[e]verything

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