Error and/or relief
In this People’s appeal from the order of the juvenile court denying its motion to transfer the juvenile matter to adult court, the order retaining jurisdiction in juvenile court is affirmed, even though the respondent is well over 25 years of age.
First Holding:
We review the juvenile court’s ruling on a transfer motion for abuse of discretion. The court’s factual findings are reviewed for substantial evidence, and its legal conclusions are reviewed de novo. A decision based on insufficient evidence or the court’s erroneous understanding of applicable law is subject to reversal. But we do not reweigh the evidence and we do not substitute our discretion for the discretion exercised by the trial court. We draw all reasonable inferences in support of the court’s findings, not against them. We are concerned only with whether the circumstances reasonably justify the trier of fact’s findings. When evidence reasonably justifies the trier of fact’s findings, the opinion of the reviewing court that the circumstances might also reasonably be reconciled with a contrary finding does not warrant a reversal of the judgment.
Authority:
In re Miguel R. (2024) 100 Cal.App.5th 152, 165, 169
Kevin P. v. Superior Court (2020) 57 Cal.App.5th 173, 187
In re J.S. (2024) 105 Cal.App.5th 205, 211
Second Holding:
The ultimate question for the juvenile court in a transfer petition is whether a minor is amenable to rehabilitation before the juvenile court’s jurisdiction expires. To order a minor’s transfer to a court of criminal jurisdiction, the juvenile court must find by clear and convincing evidence that the minor is not amenable to rehabilitation while under the jurisdiction of the juvenile court, which for persons 25 years or older extends for up to two years from the date of disposition. the prosecution bears the burden of proving by clear and convincing evidence that the minor is not amenable to rehabilitation while under the jurisdiction of the juvenile court.
Authority:
WIC 607(d) [The court may retain jurisdiction over a person who is 25 years of age or older for a period not to exceed two years from the date of disposition if the person is found to be a person described in Section 602 by reason of the commission of an offense listed in subdivision (b) of Section 707. The court shall exercise jurisdiction in conformance with the objectives of the juvenile court.]
WIC 707(a)(3)
In re E.P. (2023) 89 Cal.App.5th 409, 416
In re Miguel R. (2024) 100 Cal.App.5th 152, 167
Third Holding:
In making that determination, the juvenile court must consider five specific factors. The statute also sets forth a nonexhaustive list of relevant factors for the juvenile court to consider with respect to each of the five criteria. If the juvenile court orders a transfer to criminal court, it must recite the basis for its decision in an order entered upon the minutes, which shall include the reasons supporting the court’s finding that the minor is not amenable to rehabilitation while under the jurisdiction of the juvenile court.
Authority:
WIC 707(a)(3)
In re J.S. (2024) 105 Cal.App.5th 205, 212
Fourth Holding:
The language used in a statute or constitutional provision should be given its ordinary meaning, and if the language is clear and unambiguous there is no need for construction, nor is it necessary to resort to indicia of the intent of the Legislature (in the case of a statute) or of the voters (in the case of a provision adopted by the voters). Courts generally must accord significance, if possible, to every word, phrase and sentence in pursuance of the legislative purpose, and a construction making some words surplusage is to be avoided.
The words of the statute must be construed in context, keeping in mind the statutory purpose, and statutes or statutory sections relating to the same subject must be harmonized, both internally and with each other, to the extent possible. We examine statutory language, not in isolation, but in the context of the statutory framework as a whole to discern its scope and purpose and to harmonize the various parts of the enactment.
Authority:
People v. Valencia (2017) 3 Cal.5th 347, 357
Lungren v. Deukmejian (1988) 45 Cal.3d 727, 735
Dyna-Med, Inc. v. Fair Employment and Housing Com. (1987) 43 Cal.3d 1379, 1387
People v. Prudholme (2023) 14 Cal.5th 961, 975
Fifth Holding:
Language in a judicial opinion is to be understood in accordance with the facts and issues before the court. An opinion is not authority for propositions not considered. Thus, a decision is authority only for the points actually involved and actually decided.
Authority:
People v. Knoller (2007) 41 Cal.4th 139, 154–155
People v. Brooks (2017) 3 Cal.5th 1, 110
Sixth Holding:
Failure to offer reasoned analysis of an issue constitutes a waiver. When an appellant fails to raise a point, or asserts it but fails to support it with reasoned argument and citations to authority, we treat the point as waived. The People’s failure to develop a legal analysis that is tethered to the issue they raised and is supported by relevant authority compels rejection of their claim of error. We will not develop that analysis for them.
Authority:
Rule 8.204(a)(1)(B) [Each brief must state each point under a separate heading or subheading summarizing the point, and support each point by argument and, if possible, by citation of authority]
Trinity Risk Management, LLC v. Simplified Labor Staffing Solutions, Inc. (2021) 59 Cal.App.5th 995, 1008
Perry v. City of San Diego (2021) 65 Cal.App.5th 172, 188, fn. 8 [It is not this court’s role to connect the dots]