In re R.K.S.

Summary

The District of Columbia Court of Appeals held that R.K.S., a juvenile adjudicated delinquent for unauthorized use of a vehicle and receiving stolen property, was denied the effective assistance of counsel. The court concluded that the ineffective-assistance claim could be reviewed on direct appeal because the trial record extensively addressed counsel’s conduct and the District was not prejudiced by the absence of a separate collateral motion. The court reversed the convictions and remanded for a new trial.

Holdings

1. An ineffective-assistance claim may be reviewed on direct appeal when the trial record contains extensive evidence concerning counsel's conduct and the government was not prejudiced by the absence of a separate collateral motion.
2. A juvenile respondent facing delinquency charges and possible institutional commitment has a constitutional due process right, a statutory right, and a Superior Court rule-based entitlement to counsel, and counsel's complete failure to subject the prosecution's case to meaningful adversarial testing constitutes ineffective assistance warranting a new trial.
3. The evidence was sufficient to support the unauthorized-use-of-a-vehicle adjudication and permitted the government to retry R.K.S. on that charge.
4. The evidence was sufficient to support a finding that R.K.S. possessed the stolen Camry for his own benefit, subject to any defense of duress, and therefore permitted retrial on the receiving-stolen-property charge.

Questions Presented

1. Whether the Court of Appeals could review R.K.S.'s ineffective-assistance-of-counsel claim on direct appeal without a separate motion for a new factfinding hearing.
2. Whether counsel's complete nonparticipation during the first day of the juvenile trial denied R.K.S. his constitutional, statutory, and rule-based rights to effective assistance of counsel.
3. Whether the trial court's remedial measures were sufficient to cure the denial of counsel.
4. Whether the evidence was sufficient to support the unauthorized-use-of-a-vehicle adjudication.
5. Whether the evidence was sufficient to support the receiving-stolen-property adjudication and permit retrial on that charge.

Disposition

reversed_and_remanded