A 16-year-old student shot his former girlfriend twice in the school cafeteria. He also fired at her current boyfriend, but missed. There were multiple students and teachers in the cafeteria when the shooting took place. The student was arrested and charged with two counts of aggravated assault with a deadly weapon, two counts of deadly conduct, terroristic threat and possession of a firearm at a place weapons are prohibited. The juvenile court found that the teen should be tried as an adult for these offenses and the student appealed that decision.

The court of appeals held that the student should be tried as an adult. In doing so, it considered four factors:

  1. Whether the alleged offense involved persons or property;
  2. The sophistication and maturity of the child;
  3. The record and previous history of the child; and
  4. Protection of the public and likelihood of rehabilitation of the child.

In this case, it was undisputed that the crimes were committed against two people, the shooter's ex-girlfriend and her current boyfriend. The fact that the student was sophisticated and mature was demonstrated by his actions in planning the crime. Specifically, the student fabricated a reason for his mother to take him to his father’s house, where he stole a gun, stored it in his desk at home, brought it to school in his backback, went into the cafeteria to confirm that his ex-girlfriend was there, and then went into the bathroom to cock the gun and put it in his pocket before returning to the cafeteria to shoot her. The court found that these factors demonstrated a lack of impulsivity and supported a finding of sophistication and maturity.

Although the student did not have a previous criminal record, he did have a significant history of behavioral problems, angry outbursts and violent behavior at school and home, including stabbing a relative’s dog to death, assaulting other students, and killing birds. Finally, the court found that due to his age, the juvenile system would be unlikely to rehabilitate him before his 19th birthday.

Based on the above factors, the court of appeals concluded that the student should be tried as an adult for his alleged crimes and upheld the decision of the juvenile court.