In re M.N.T.

Summary

The District of Columbia Court of Appeals held that victim impact statements are not categorically excluded from juvenile disposition hearings. Such statements may be admitted when material and relevant to rehabilitation and public safety, subject to the court's discretion. The court further held that statements the government intends to introduce must be included, or summarized, in the predisposition report provided to juvenile counsel, although the notice error in this case was harmless.

Holdings

1. Victim impact statements are not categorically prohibited in juvenile disposition hearings; a judge may admit them in the sound exercise of discretion when they are material and relevant to disposition and their admission is otherwise within statutory limitations.
2. Any victim impact statement that the government intends to introduce at a juvenile disposition hearing should be included in the predisposition report and furnished to juvenile counsel in accordance with the applicable juvenile-proceeding rule.
3. The trial court erred by denying M.N.T. the advance opportunity to respond to the victim impact statements, but the error did not affect the disposition and did not warrant reversal or a new hearing.

Questions Presented

1. Whether victim impact statements are categorically inadmissible in juvenile disposition proceedings.
2. Whether the government was required to provide advance notice of the contents of intended victim impact statements through the predisposition investigation report.
3. Whether the trial court's failure to provide M.N.T. with advance notice and an opportunity to respond required a new disposition hearing or other relief.

Disposition

affirmed