Corder v. Rogerson

192 F.3d 1165 (8th Cir. 1999)

Facts

P killed his stepmother and burned down the family residence when he was sixteen years old. The crime occurred on March 25, 1987. The State filed a Petition Alleging Delinquent Act against P in the Juvenile Division of the Jackson County District Court. The Court issued a warrant for P’s arrest after finding probable cause to believe that he had committed murder and arson based upon an affidavit by an Iowa criminal investigator describing incriminating evidence and witness statements. The State filed a motion asking the juvenile court to waive its jurisdiction so that P could be tried as an adult. The court relied on its previous finding of probable cause and did not hold a hearing or any other type of process. P was then tried as an adult, and a jury convicted him of first-degree murder and second-degree arson. P appealed, contending that the juvenile court denied him due process in waiving jurisdiction because it found probable cause on the basis of the State’s complaint and affidavit, without hearing any witnesses. The Iowa Court of Appeals affirmed. The Iowa Court of Appeals also affirmed the trial court’s denial of P’s application for state post-conviction relief, an application that did not revisit the juvenile court’s proceedings. P then filed this federal habeas petition. The district court denied relief but granted a certificate of appealability on the question whether P’s “due process rights were violated in the waiver process by which [he] was transferred from juvenile to district court.”