Missouri Court of Appeals, Southern District / Oct 19, 2018
In the Interest of K.L.C., a minor. K.L.C., Minor-Appellant vs. REYNOLDS COUNTY JUVENILE OFFICER, Petitioner-Respondent
K.L.C., a minor, appealed a delinquency judgment of adjudication, arguing the trial court erred by applying a "clear, cogent and convincing evidence" standard of proof instead of "beyond a reasonable doubt." The Juvenile Officer conceded the error. The appellate court reversed and remanded, holding that the constitutionally mandated standard of proof in juvenile delinquency proceedings for acts that would be crimes for adults is "beyond a reasonable doubt," and the trial court's use of a lesser standard constituted a structural defect.