At the adjudicatory hearing, the State presented the following evidence. While changing class periods, Appellant approached another student in the hallway and they engaged in a tense verbal exchange. After pushing each other, the two began to scuffle and other students gathered around the scene making it difficult to pass through the hallway. One of the onlookers pulled the backpack off the other student during the fight. The physical altercation lasted for less than one minute before school officials arrived, broke up the fight, and chased the onlookers away.
At the close of the State's evidence, defendant's counsel moved for a judgment of dismissal. The trial court denied the motion because of the crowd of onlookers the scene created and because the number of officials that reported to the scene were “a little bit more than necessary to . . . just monitor the hallways.”
The court entered an order finding the State proved beyond a reasonable doubt that Appellant committed disruption of an educational institution as charged. After a disposition hearing, the court withheld adjudication of delinquency and placed defendant on probation.
The evidence that there was an unplanned short fight between two students is, standing alone, generally insufficient to show the intent required to violate the statute.
The standard of review that applies to motions for judgment of dismissal in a juvenile case is the same standard that applies to motions for judgment of acquittal in an adult criminal case. When a defendant asks for a judgment of acquittal, a defendant admits both the facts, as well as every conclusion favorable to the State that a judge could fairly and reasonably find from the evidence. Evidence is sufficient to uphold a conviction if the judge could find proof of the elements of the crime beyond a reasonable doubt after viewing the evidence in a light most favorable to the State.
Applying this standard of review, the appeals court agreed with the defendant's argument that the trial court erred in denying his motion for judgment of dismissal as to this charge. Adjudication reversed.