The People of the Territory of Guam v. Edwin A. Quinata

This case concerns whether the Juvenile Court of Guam has jurisdiction when criminal charges are filed after a defendant’s eighteenth birthday, alleging crimes committed before he reached that age. For reasons set forth below, we hold the appellate division of the Guam District Court was correct in concluding that the juvenile court has jurisdiction in the case described. Before stating the reasons for our conclusion, we find it necessary to discuss also whether the appellate division ruling, which reversed the juvenile court’s order of dismissal and directed it to proceed in the case, is reviewable here.

Appellant, Edwin A. Quinata, has been charged with participating in a fatal assault. The crime allegedly occurred on November 18, 1980; Quinata turned eighteen years old on November 19, 1980; he was arraigned and charged on November 20, 1980. The Government filed the November 20 charges in the Superior Court of Guam, but Quinata challenged that court’s jurisdiction and the Government dismissed the case, refiling in the juvenile court. The juvenile court ruled that it lacked jurisdiction and dismissed. The Government appealed to the Appellate Division of the District Court of…