Collins v. State
908 S.W.2d 80, 1995 Ark. LEXIS 608, 322 Ark. 161 (1995)
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Rule of Law:
A juvenile court’s decision to transfer a case to circuit court for adult prosecution must be supported by clear and convincing evidence, considering the seriousness of the offense, repetitive patterns of conduct, and the juvenile’s history and prospects for rehabilitation.
Facts:
- On July 15, 1994, Criminal Investigator Ray Shoptaw was conducting surveillance near Ronald Collins' (age 16) home in Hot Springs due to numerous local burglaries and thefts, with Collins and his brother considered suspects by the sheriff's office.
- Shoptaw observed Collins, his brother, and another adult male walk into nearby woods with nothing in their hands, and about 90 minutes later heard gunshots and muffled voices from the same area.
- A short while later, Shoptaw saw Collins and his two companions walk out of the wooded area carrying items.
- All three individuals were arrested for residential burglary; Collins' companions were found with a .22 caliber revolver, a .22 derringer, various pieces of jewelry, gloves, and a large screwdriver, all later identified as stolen.
- Collins was found with a pair of gloves and a pistol holster, which were also identified as stolen items from a residence burglary.
- One of Collins' companions admitted to officers that the three had committed this burglary and another burglary on the previous day.
- At the time of his arrest, Collins was already out on bond for a pending burglary charge.
- Collins had a prior record including a dismissed third-degree battery charge, a conviction for failure to appear and obstructing governmental operations (resulting in probation and a suspended sentence), and a probation violation for failing to report and leaving the county; he was uncooperative on probation and did not utilize available counseling.
Procedural Posture:
- The State filed a motion in juvenile court to transfer Ronald Collins' case from juvenile court to circuit court.
- A transfer hearing was conducted in juvenile court on August 4, 1994, with testimony from the arresting officer, Collins' probation officer, and Collins' mother.
- The juvenile court granted the State’s motion to transfer, finding by clear and convincing evidence that the matter should be transferred to circuit court.
- Ronald Collins filed an interlocutory appeal of the juvenile court's decision to the Supreme Court of Arkansas.
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Issue:
Does a juvenile court commit clear error by finding, by clear and convincing evidence, that a 16-year-old charged with a serious felony involving firearms and having a history of uncooperative probation should be transferred to circuit court for trial as an adult?
Opinions:
Majority - Andree Layton Roaf, Justice
Yes, the juvenile court did not commit clear error in transferring Ronald Collins' case to circuit court for trial as an adult because there was clear and convincing evidence to support the decision. The court reasoned that Collins was charged with a serious Class B felony, firearms were involved "at least collaterally" through his association with companions possessing them, and the offense was part of a repetitive pattern of conduct, as evidenced by his existing bond for another burglary charge and his history of non-cooperation with probation. The court also considered Collins' history, character traits, and maturity, noting his failure to report to probation, lack of engagement with counseling, and prior legal issues, which collectively suggested he was "beyond the current rehabilitation available" in the juvenile system. The court affirmed that the lower court is not required to give weight to each statutory factor or have proof on each factor, and cited precedents such as Sebastian v. State and Walter v. State to support its interpretation of the factors, particularly regarding repetitive patterns and collateral involvement with violence.
Analysis:
This case underscores the significant discretion afforded to juvenile courts in transfer decisions, emphasizing that appellate courts will only reverse such rulings if "clearly erroneous." It clarifies that not all statutory factors must be proven or equally weighted, and that even indirect involvement with violence (e.g., through association with armed accomplices) can satisfy the "violence" criterion. The ruling highlights the importance of a juvenile's prior history of offenses and their response to rehabilitation efforts in determining their prospects for successful treatment within the juvenile justice system.
