The trial court has broad discretion in choosing the appropriate juvenile delinquency disposition and its decision will be affirmed as long as it is not arbitrary. Absent a clear abuse of discretion, a trial court's disposition will not be disturbed. The purpose in delinquency dispositions is the rehabilitation and the restoration of law-abiding conduct in the juvenile. In a delinquency disposition, the court must take the least drastic step to restore law-abiding conduct. J.L.M. argues that the district court committed reversible error when it failed to make written findings of fact to support its disposition.
Findings regarding guilt are sufficient if in writing or on the record.
The failure to make the statutorily required findings constitutes reversible error. In the present case, the district court failed to make any written findings that the aims of the law could not be satisfied without removal of the child from the home, or that the placement at the Leo Hoffman Center was suitable for J.L.M.'s needs. Minnesota case law is uniformly clear that it is reversible error for a court not to make the statutorily required findings. The court simply checked a box on a preprinted form that the disposition is in J.L.M.'s best interests. Findings on the record or on a preprinted form are insufficient.