Griffith v. State

BAKER, Judge,

dissenting.

I respectfully dissent from the majority’s holding that “the trial court was without jurisdiction of the particular case to hear and decide the charges against Griffith of theft, carrying a handgun without a license, and criminal confinement.” Op. at 240. Specifically, because the majority erroneously construes our statute regarding waiver of juvenile cases to adult court, because the majority ignores an inherent finding that commitment to the juvenile justice system is not in Griffith’s best interest, and because judicial economy is best served by either retaining jurisdiction over all counts or waiving all counts, I would affirm Griffith’s convictions.

I. Severance of Counts

The majority interprets our juvenile waiver statute, Indiana Code section 31-30-3-1, as prohibiting the waiver of non-included offenses to adult court. Specifically, the majority avers that because théft, carrying a handgun without a license, and criminal confinement are not offenses included within the definitions of felony murder and robbery, the trial court was without jurisdiction over these crimes. Id.

*242I first note that the language of our statute that defines waiver of jurisdiction reads as follows:

Waiver of jurisdiction refers to an order of the juvenile court that waives the case to a court that would have jurisdiction had the act been committed by an adult. Waiver is for the offense charged and all included offenses.

Ind. Code § 31-30-3-1. The first sentence notes that it is the case that is waived to adult court. The statute is devoid of language allowing for the severance of charges.13 Yet, the majority’s opinion infuses the statute with just such a meaning.

Moreover, the majority seemingly ignores the deference that we typically afford to juvenile courts when such courts— as in this case—decide to waive jurisdiction over a juvenile. Juvenile courts are in a far better position to determine whether charges should be tried in adult court because of the specific circumstances of that juvenile’s case. Tapia v. State, 753 N.E.2d 581, 585 (Ind.2001) (holding that the trial court “is given discretion to act on an issue when it is in a better position than an appellate court to evaluate the factual context surrounding the issue”). The result of the majority’s opinion is a cookie-cutter approach that disregards the juvenile court’s superior position. In my view, the juvenile court was correct in refusing to sever the charges upon making the determination that rested within its discretion to waive Griffith’s case to adult court. II. Inherent Juvenile Court Finding

I would also note that the majority ignores an important implied finding of the juvenile court. Specifically, the majority ignores the fact that inherent in a waiver to adult court is a finding that the juvenile defendant is beyond the assistance of the juvenile justice system.

Indiana Code section 31-30-3-4, the juvenile waiver statute for a child charged with murder, reads:

Upon motion of the prosecuting attorney and after full investigation and hearing, the juvenile court shall waive jurisdiction if it finds that:
(1) the child is charged with an act that would be murder if committed by an adult;
(2) there is probable cause to believe that the child has committed the act; and
(3) the child was at least ten (10) years of age when the act charged was allegedly committed;
unless it would be in the best interests of the child and of the safety and welfare of the community for the child to remain within the juvenile justice system.

(emphasis added). Thus, when a waiver occurs, the juvenile court necessarily determines that it is in the juvenile’s best interest—and in the interest of the community—that the juvenile not remain within the juvenile justice system. In essence, the judge is satisfied that the tools given to the juvenile court are not adequate to reform the offender.

Here, Griffith held two victims at gunpoint, took possession of a vehicle through threat of force, and murdered David Whit-lock. Inherent in the trial court’s waiver of jurisdiction was a finding that it is in Griffith’s best interest—and that of the community—to be removed from the juvenile justice system. In a Kafkaesque step, the majority’s decision to reverse the trial court and keep Griffith’s theft, carrying a *243handgun without a license, and criminal confinement charges in juvenile court actually results in committing Griffith to a system where the trial court found that his best interests will not be met.

III. Judicial Economy

The majority admits that its decision “duplicated judicial action and waste[s] an inordinate amount of judicial resources.” Op. at 241 n. 12. The majority then moves to trivialize this fact by stating that because Griffith received a fifty-five year sentence for murder, “any additional proceedings would have a negligible effect upon Griffith.” Id.

The short shrift given to judicial economy by the majority’s opinion notwithstanding, we note that the importance of judicial economy cannot be understated. In 2001, the latest year for which statistics are available, 25,547 juvenile delinquency petitions were filed in our circuit and superior courts, an increase of nearly 60% since 1992. 2001 Indiana Judicial Report, Supreme Court of Indiana, 69. At the same time, the number of circuit, superior, and county court judges increased only from 264 to 298, a 13% increase. Id. at 110; 1992 Indiana Judicial Service Report, Supreme Court of Indiana, 94. Thus, the “bifurcation” foisted on juvenile and trial courts by the majority will undoubtedly place further strain on our judicial system. Henceforth, both a juvenile and trial court will have to listen to the same witnesses, view the same evidence, and consider the same arguments made by counsel when a single trial court could easily handle these tasks. To me, such a posture surely amounts to a waste of taxpayer dollars and contributes to the strain upon our judicial resources. This being said, I would affirm the trial court.

. In contrast, Indiana Code section 35-34-1-11(a) provides a specific framework for the severance of criminal charges.