In the Interest of: J.J.G., Jr. vs. Juvenile Officer

CourtMissouri Court of Appeals
DecidedJuly 8, 2025
DocketWD87140
StatusPublished

This text of In the Interest of: J.J.G., Jr. vs. Juvenile Officer (In the Interest of: J.J.G., Jr. vs. Juvenile Officer) 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.J.G., Jr. vs. Juvenile Officer, (Mo. Ct. App. 2025).

Opinion

In the Missouri Court of Appeals Western District IN THE INTEREST OF: J.J.G., JR., ) ) Appellant, ) ) WD87140 v. ) OPINION FILED: ) JULY 8, 2025 JUVENILE OFFICER, ) ) Respondent. )

Appeal from the Circuit Court of Jackson County, Missouri The Honorable Jennifer M. Phillips, Judge

Before Division Four: Anthony Rex Gabbert, Chief Judge, Presiding, Karen King Mitchell, Judge, Janet Sutton, Judge

J.J.G. appeals the judgment of the Jackson County Circuit Court finding he is in

need of care and treatment under Chapter 211 of the Revised Statutes if Missouri. In his

sole point on appeal, J.J.G. argues the court clearly erred and abused its discretion

because the judge who entered the judgment did not have any evidence presented to her.

The judgment is affirmed.

Facts

In June 2023, the Juvenile Officer filed a petition in the Jackson County Circuit

Court alleging J.J.G. is in need of care and treatment. The petition alleged three counts

that occurred before J.J.G.’s fourteenth birthday. Count I alleged that J.J.G. had deviate

sexual intercourse with a person less than twelve years old by inserting his penis into the victim’s mouth in violation of section 566.0621 (statutory sodomy in the first degree).

Count II alleged that J.J.G. had deviate sexual intercourse with a person less than twelve

years old by inserting his penis into the victim’s anus in violation of section 566.062

(statutory sodomy in the first degree). Count III alleged that J.J.G. subjected a person

less than twelve years old to sexual contact by touching his penis to the victim’s back in

violation of section 566.068 (child molestation in the second degree).

The case was assigned to a commissioner (“Commissioner”). Commissioner held

a hearing on the petition in January 2024. Four witnesses testified, and Commissioner

received three exhibits. Commissioner entered an order upon adjudication hearing in

February 2024. The order stated in relevant part:

The Court DENIES the Juvenile’s Motion to for [sic] a judgement [sic] of acquittal at the close of the Juvenile Officer’s evidence.

The Court DENIES the Juvenile’s Motion for Acquittal at the close of all evidence.

The Court having observed the demeanor of the witnesses, evaluated credibility, and resolved any conflicts or inconsistencies in testimony and evidence, finds that the evidence adduced sustains the allegations in Counts 1, 2 and 3 beyond a reasonable doubt. Therefore the Petition is hereby SUSTAINED.

The order was signed by Commissioner.

Commissioner held a disposition hearing in April 2024. The deputy juvenile

officer testified and a victim impact statement was read. Commissioner announced she

1 Statutory citations refer to the 2016 edition of the Revised Statutes of Missouri, updated by the 2024 Cumulative Supplement.

2 would follow the recommendation of the deputy juvenile officer to impose a suspended

residential commitment and place J.J.G. on probation.

Commissioner reduced her findings and recommendations to writing, which she

signed, on April 15, 2024. That document stated in relevant part:

Notice of Findings and Recommendation & Notice of Right to Rehearing The parties are notified that the foregoing Findings and Recommendations have been entered this date by a commissioner, and all papers relative to the case or proceeding, together with the Findings and Recommendation have been transferred to a Judge of the Court. The Findings and Recommendations shall become the Judgment of the Court upon adoption by order of the Judge. Unless waived by the parties in writing, a party to the case or proceeding heard by a commissioner, within fifteen days after the mailing of notice of the filing of the Judgment of the Court, may file a motion for rehearing by a Judge of the Court. If the motion for rehearing is not ruled on within forty-five days after the motion is filed, the motion is overruled for all purposes. Rule 130.13.

A judgment adopting the findings and recommendations was entered the next day by a

Jackson County Circuit Court Judge.

This appeal follows.

Standard of Review

“We review juvenile proceedings in the same manner as other court-tried cases.”

Z.G. v. Juv. Officer, 702 S.W.3d 262, 268 (Mo. App. W.D. 2024) (internal quotation

marks omitted). “Accordingly, we will affirm a judgment in a juvenile proceeding unless

it is not supported by evidence, is against the weight of evidence or erroneously declares

or applies the law.” Id. (internal quotation marks omitted). “We review questions of law

de novo.” Interest of A.J.C., 698 S.W.3d 444, 447 (Mo. App. W.D. 2024).

3 Analysis

In his sole point on appeal, J.J.G. argues that the Jackson County Circuit Judge

who entered judgment lacked authority because evidence was presented to a

commissioner instead of a circuit court judge. He claims that, in his case, no person

authorized to exercise the judicial power of the State of Missouri received evidence or

determined the allegations in the petition beyond a reasonable doubt. Instead of a circuit

judge, it was a commissioner who held the adjudication and disposition hearings, heard

testimony, reviewed exhibits, and found that the evidence sustained the allegations in the

petition. J.J.G. states that the commissioner could not exercise the judicial power of the

State of Missouri.

In Slay v. Slay, 965 S.W.2d 845 (Mo. banc 1998), the Missouri Supreme Court

held that documents signed by a commissioner do not constitute final appealable

judgments because they “are not signed by a person selected for office in accordance with

and authorized to exercise judicial power by article V of the state constitution.” A few

months after the Slay decision, the Missouri Supreme Court held in State ex rel. York v.

Daugherty, 969 S.W.2d 223, 225 (Mo. banc 1998), that any party who fails to challenge

the commissioner's “judgment” waives the right to object to that “judgment” and any

party who assumes the benefits or burdens of the “judgment” is estopped from attacking

it. Thus, as to any such party “the commissioner’s findings and recommendations are as

conclusive as if entered as the judgment of an article V judge.” Id.

4 Missouri Supreme Court Rule 130 became effective on January 1, 2010. It

pertains to family court division commissioners. Rule 130 “is promulgated pursuant to

the authority granted this Court by article V, section 5 of the Constitution of Missouri and

supersedes all statutes and existing court rules inconsistent therewith.” Rule 130.02.

The functions and powers of the commissioner shall be to hear and make findings and recommendations in cases or proceedings assigned to the commissioner by general or special order of the administrative judge. The commissioner shall have the same powers and authority to manage those assigned cases and proceedings as would a judge, but the commissioner shall have no other administrative functions unless such functions are assigned by the administrative judge.

Rule 130.04. “The administrative judge may direct that any case … pending in the court

be heard by the commissioner in the manner provided for hearing of cases by law and

may direct that detention hearings, informal hearings, and hearings … shall be heard in

the first instance by the commissioner.” Rule 130.05. “In each case heard by the

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Related

State Ex Rel. York v. Daugherty
969 S.W.2d 223 (Supreme Court of Missouri, 1998)
Marriage of Slay v. Slay
965 S.W.2d 845 (Supreme Court of Missouri, 1998)
In Re Finnegan
327 S.W.3d 524 (Supreme Court of Missouri, 2010)

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