In the Interest of A.B. 2025 Mo. LEXIS 667 (Mo. 2025)

The Missouri Court of Appeals, Western District held that courts must ensure that a juvenile court admission is voluntarily, knowingly and intelligently made, and requires the court to establish a factual basis.

The court stated in relevant part: ““A plea of guilty is constitutionally valid only to the extent it is ‘voluntary’ and ‘intelligent.’” Booker v. State, 552 S.W.3d 522, 527 (Mo. banc 2018) (internal quotation marks omitted). “[I]f a defendant’s guilty plea is not equally voluntary and knowing, it has been obtained in violation of due process and is therefore void.” Id. (internal quotation marks omitted). “Additionally, because a guilty plea is an admission of all the elements of a formal criminal charge, it cannot be truly voluntary unless the defendant possesses an understanding of the law in relation to the facts.” Id. (internal quotation marks omitted).

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This court has previously addressed whether juvenile admissions were voluntary, knowing, and intelligent. In both A.J.L.G., 679 S.W.3d 556 and A.L.H. v. Juv. Officer, 676 S.W.3d 484 (Mo. App. W.D. 2023), this court reversed and remanded because the
circuit court failed to comply with Rule 128.02. The Juvenile Officer argues that A.J.L.G. and A.L.H. are distinguishable because the courts in those cases made no inquiry at all when accepting the juvenile’s admission while, as set forth above, the circuit court in this
case made an inquiry into A.B.’s admission.

We agree that the circuit court in this case did question A.B. about his admission in contrast to what occurred in A.J.L.G. and A.L.H. However, as set forth in the transcript above, A.B.’s admission never identified the crime as assault in the second degree. A.B. was not asked at all about the conduct to which he was admitting. Moreover, A.B. was never asked if he committed the crime and never stated that he did. We also note that A.B. was not an adult and that concerns were raised prior to the court’s acceptance of A.B.’s admission that he might not understand what was occurring during the proceedings.”