The Missouri Court of Appeals, Western District, has overturned a lower court’s decision in the case of A.B., a juvenile who was found to have committed second-degree assault. The appeals court ruled that the lower court made a mistake by accepting A.B.’s admission of guilt without properly ensuring it was made knowingly, voluntarily, and intelligently. As a result, the case is being sent back to the lower court for further proceedings.
The Background of the Case
The case began in October 2023 when the Juvenile Officer filed a petition alleging that A.B. was in need of care and treatment due to physical abuse by his mother. Later, an amended petition was filed which added allegations of assault, property damage, and stealing. However, these delinquency allegations were later dropped. The court found the remaining allegations regarding the mother’s abuse to be true, and A.B. was placed with his mother in the custody of Children’s Division.
In February 2024, a second amended petition was filed, including the previously dismissed delinquency allegations. A third amended petition followed in April 2024, without new delinquency allegations.
The fourth amended petition, filed eleven days later, included a crucial allegation: that A.B. committed second-degree assault on April 25, 2024, at a residential facility. The petition stated that A.B. punched a staff member multiple times, pulled out her hair, and spat on her. The staff member required stitches.
The Admission and the Court’s Actions
In July 2024, during the trial, the Juvenile Office agreed to dismiss most of the allegations, with the exception of the second-degree assault charge (paragraph 4f of the fourth amended petition). The court then asked A.B. and his defense counsel about this agreement. A.B.’s defense counsel stated that A.B. would admit to the allegation in paragraph 4f.
A.B.’s mother objected to the agreement, expressing concerns about A.B.’s disability and her belief that he didn’t fully understand what he was agreeing to. She also stated she was consulting an attorney to hire on his behalf. Despite this, the court accepted the announcements from the Juvenile Office and A.B.
The court then questioned A.B. to determine if his admission was knowing and voluntary. The court asked A.B. if he understood the proceedings, if he had discussed the matter with his attorney, and if he was making the admission without any threats or promises. A.B. answered “yes” to most of these questions. The court found A.B.’s admission to be knowing and voluntary.
Based on the admission, the court found the allegation in paragraph 4f to be proven and committed A.B. to the Division of Youth Services until his eighteenth birthday.
The Appeals Court’s Reasoning
A.B. appealed the decision, arguing that the lower court plainly erred in accepting his admission because it was not made knowingly, voluntarily, and intelligently. The appeals court agreed.
The appeals court highlighted that, while juvenile proceedings are civil, they still require due process, particularly when a child’s liberty is at stake. Missouri law requires a court to ensure that a juvenile’s admission is voluntary, knowing, and intelligent, and that there is a factual basis for the admission.
The appeals court found that the lower court failed to meet these requirements. Specifically, the court did not ask A.B. if he understood he was presumed innocent, that the Juvenile Officer had the burden to prove his guilt beyond a reasonable doubt, that he could confront witnesses, that witnesses could be subpoenaed, or that he had the right to testify or not. The court also did not specifically identify the crime of assault in the second degree, nor did it ask A.B. if he committed the assault. The appeals court noted that A.B. was never asked about the conduct to which he was admitting. The court concluded the record did not support the lower court’s finding that a factual basis for the admission existed.
The appeals court emphasized that the lower court’s failure to comply with these rules constituted plain error, resulting in a manifest injustice. The court stated that the protections in place are designed to safeguard a juvenile’s rights and that a defective plea deprives the juvenile of these protections.
The Outcome
Because of the errors, the Missouri Court of Appeals reversed the lower court’s judgment. The case has been sent back to the lower court for further proceedings, likely including a new determination of whether A.B. committed the assault.