William Mitchell Law Review

Publication Information

30 William Mitchell Law Review 427 (2003-2004)


In 1995, Minnesota created a blended sentencing option for serious, violent juvenile offenders. Under this new option, Extended Juvenile Jurisdiction (“EJJ”), the juvenile court retains jurisdiction over the offender until age 21. In EJJ cases the court also imposes an adult sentence, which is stayed on the condition that the offender complies with the conditions of probation. Since the passage of the EJJ statute, the Minnesota Supreme Court has issued a limited number of opinions reviewing EJJ cases. State v. B.Y., issued April 24, 2003, involves an issue of first impression. The B.Y. opinion addresses standards to be applied in EJJ probation revocation proceedings, holding that adult revocation standards apply to EJJ proceedings. This case note provides a historical background of the EJJ statute and probation revocation process in order to provide context for analysis of the B.Y. decision. A brief description of the facts and the court's analysis presents further background information for the court's decision. The note goes on to discuss and explain the court's decision in light of applicable statutes and case law. This case note seeks to address the two central questions that arise from the B.Y. decision: first, whether the application of adult revocation standards to EJJ revocation proceedings is justified under the EJJ statute and other principles of law; and second, whether the Minnesota Supreme Court applied the analysis used in adult proceedings to the B.Y. case in a way that provides future guidance to lower courts.