In re Juvenile Appeal

Connecticut Supreme Court · Family Law

Family LawJuvenile DelinquencySufficiency of the EvidenceCredibility of Witnessesjuvenile delinquencydisorderly conductsufficiency of evidencecredibility

Facts

After police responded to a complaint that boys were playing football on a Waterbury street, the officers told the group to stop and return to their school bus stop. According to one officer, the respondent refused to comply with the order to disperse and made sarcastic and abusive statements; defense witnesses testified that he made no derogatory statements. The respondent was the only person arrested. After a full hearing, the trial court found him delinquent for violating the disorderly conduct statute.

Issue

Whether there was sufficient evidence to support the adjudication of the respondent as a delinquent child for disorderly conduct. The appeal also raised whether the trial court's acceptance of the officer's testimony over the respondent's witnesses showed racial bias in violation of the state constitution.

Rule

A juvenile delinquency adjudication is reviewable as a final judgment even when the child is given a warning and the matter is otherwise dismissed from further court accountability. On appellate review, credibility determinations belong to the trier of fact, and a finding based on testimony the trial court credits will not be overturned merely because opposing testimony was corroborated or because the parties were of different races absent proof of racial bias in the record.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Hartford, a Family Division judge found sixteen-year-old Noah Bennett delinquent after a hearing. The judge then stated, "I am issuing only a warning and dismissing him from further court supervision," and closed the file.

If Noah appeals the delinquency finding, the strongest argument that the appellate court has jurisdiction is that

Explanation. The majority treated an adjudication of delinquency as a final judgment even when the child was later "dismissed" with a warning. In that context, dismissal meant only the end of further accountability or supervision, not the undoing of the adjudication itself. Thus the adjudication remained reviewable. (Derived from In re Juvenile Appeal (n.d.).)