Criminal Law; Juvenile Law; Discovery

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WI Court of Appeals – District I

Case Name: State of Wisconsin v. Jayden Adams

Case No.: 2023AP000218-CR

Officials: Geenen, J.

Focus: Criminal Law; Juvenile Law; Discovery

Adams, a juvenile charged with first-degree reckless homicide, sought discovery of evidence prior to his preliminary examination to negate the charges and argued for a reverse waiver to be tried in juvenile court.

The court ruled that under State v. Kleser, juveniles are entitled to the evidence the State plans to use at the preliminary examination but must demonstrate a particularized need for additional discovery. Adams failed to show this need, leading to the denial of his discovery request. Furthermore, the court upheld the denial of the reverse waiver, stating that Adams did not prove he could not receive adequate treatment in the adult system or that transferring to juvenile court would not depreciate the seriousness of his offense.

The court maintained that the circuit court properly applied the legal standards and did not abuse its discretion in its decision, thus affirming the lower court’s order to retain adult criminal jurisdiction over Adams​.

Affirmed.

Decided 07/16/24

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