In the Matter of J.C.N.-V.

J.C.N.-V. (defendant) was a 13-year-old child who participated in a violent murder and robbery. After his arrest, J.C.N.-V. was initially deemed to be in the exclusive jurisdiction of the juvenile court. The state then petitioned to waive J.C.N.-V. into the adult-court system, contending that J.C.N.-V. had the requisite maturity to understanding of his actions. Experts testified that J.C.N.-V. had only average maturity for his age and that 13-year-olds are not capable of sufficient abstract thinking to possess empathy and remorse. Evidence was also introduced to show that J.C.N.-V. had a history of violence beginning at age nine and that he was amenable to treatment. Oregon’s juvenile court offered treatment only up until age 25, whereas adult court offered supervision and treatment beyond that point, making adult court preferable for a person needing continued treatment. The juvenile court granted the state’s petition and waived J.C.N.-V. into adult court, finding that J.C.N.-V. had average to above-average maturity for his age and that he understood his actions and the consequences of those actions, and emphasizing his history of violent conduct and need for treatment. J.C.N.-V. appealed. The appellate court affirmed, holding that a juvenile needed only to exhibit average maturity and understanding for his age to be eligible for waiver into adult court.