In re Interest of Aaden S.

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
In re Interest of Aaden S., a child
under 18 years of age.
State of Nebraska, appellee, v.
Aaden S., appellant.
___ N.W.3d ___
Filed February 6, 2026. 	No. S-24-947.
1. Constitutional Law: Due Process. The determination of whether the
procedures afforded to an individual comport with constitutional require-
ments for due process presents a question of law.
2. Judgments: Appeal and Error. An appellate court independently
reviews questions of law decided by a lower court.
3. Courts: Juvenile Courts: Jurisdiction: Appeal and Error. An appel-
late court reviews a juvenile court’s decision to transfer a juvenile
offender’s case to county court or district court de novo on the record
for an abuse of discretion.
4. Constitutional Law: Due Process. The U.S. and Nebraska Constitutions
provide that no person shall be deprived of life, liberty, or property with-
out due process of law.
5. Due Process. The concept of due process defies precise definition but
embodies the notion of fundamental fairness.
6. ____. Due process is flexible and calls for such procedural protections
as the particular situation demands.
7. Juvenile Courts. The object of the Nebraska Juvenile Code is correc-
tive, to the end that the child’s reformation be brought about.
8. ____. A juvenile proceeding is not a prosecution for a crime but a
special proceeding that serves as an ameliorative alternative to a crimi-
nal prosecution.
9. Parental Rights: Rules of Evidence: Due Process. While the Nebraska
Evidence Rules do not apply in juvenile proceedings, the basic require-
ments of due process oblige a court to consider the type of evidence
Nebraska Supreme Court Online Library
www.nebraska.gov/apps-courts-epub/
10/18/2026 12:58 AM CDT

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
used by the State in order to determine the weight to be given to
that evidence.
10. Rules of Evidence. Authentication is governed by Neb. Rev. Stat.
§ 27-901 (Reissue 2016) of the Nebraska Evidence Rules and does not
impose a high hurdle for admissibility.
11. ____. Authentication is often satisfied by testimony that a matter is what
it is claimed to be, but proper authentication may also be attained by
evidence of appearance, contents, substance, internal patterns, or other
distinctive characteristics, taken in conjunction with circumstances, suf-
ficient to support a finding that the matter in question is what it is
claimed to be.
12. Courts: Juvenile Courts: Jurisdiction. In determining whether a case
should be transferred to criminal court, the juvenile court need not
resolve every factor against the juvenile, and there are no weighted fac-
tors and no prescribed method by which more or less weight is assigned
to a specific factor. Rather, the court must engage in a balancing test by
which public protection and societal security are weighed against the
practical and nonproblematic rehabilitation of the juvenile.
13. Juvenile Courts: Proof. The State has the burden to prove, by a pre-
ponderance of the evidence, that a juvenile’s case should transferred to
adult court.
14. Judgments: Words and Phrases. An abuse of discretion occurs when a
trial court’s decision is based upon reasons that are untenable or unrea-
sonable or if its action is clearly against justice or conscience, reason,
and evidence.
Petition for further review from the Court of Appeals,
Riedmann, Chief Judge, and Pirtle and Arterburn, Judges,
on appeal thereto from the County Court for Buffalo County,
John P. Rademacher, Judge. Judgment of Court of Appeals
affirmed.
Charles 	D. 	Brewster, 	of 	Klein, 	Brewster, 	Brandt 	&
Messersmith, for appellant.
Marti S. Sleister, Deputy Buffalo County Attorney, for
appellee.
Funke, 	C.J., 	Cassel, 	Stacy, 	Papik, 	Freudenberg,
Bergevin, and Vaughn, JJ.

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
Freudenberg, J.
INTRODUCTION
This case concerns the question of what process is due to
a juvenile facing transfer of his case from the juvenile docket
to the adult docket of the county court. At the hearing on
the State’s motion to transfer, the only evidence offered by
the State was several exhibits that had been previously pro-
vided to the juvenile’s attorney and described by the deputy
county attorney at the hearing as “Exhibits 4 through 19,”
and contained “photos, the police reports, and the video from
the [child advocacy center] interview.” The State provided
neither witness nor affidavit to support, identify, or authen-
ticate any of the exhibits. The juvenile court overruled the
juvenile’s attorney’s objections to the evidence based on due
process, authentication, foundation, and confrontation and
granted the State’s motion to transfer the juvenile’s case to
the county court. The juvenile appealed. The Nebraska Court
of Appeals, in a split opinion, affirmed the juvenile court’s
decision, finding the juvenile’s rights to due process were not
violated and the juvenile court did not abuse its discretion in
transferring the juvenile’s case. The juvenile petitioned for
further review on both issues, which we granted. We affirm
under the specific facts of this case.
BACKGROUND
Aaden S. is a minor. In September 2024, a juvenile petition
was filed against Aaden in the Buffalo County Court alleg-
ing the offenses of (1) first degree sexual assault, a Class II
felony; (2) terroristic threats, a Class IIIA felony; (3) assault by
strangulation or suffocation, a Class IIIA felony; and (4) third
degree domestic assault, a Class I misdemeanor. The allega-
tions against Aaden stem from two August 2024 incidents in
the area of Kearney, Nebraska, that involved Aaden’s then-
girlfriend, J.Z., who was 18 years old at the time. Aaden was
16 years old at the time of the incidents.

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
Motion to Transfer Hearing
The State moved to transfer Aaden’s case from the juvenile
court to the adult docket of the county court. After Aaden’s
counsel moved for and obtained a continuance to allow for the
completion of an evaluation of Aaden, a hearing on the State’s
motion to transfer was held.
At the hearing, Aaden was present and represented by coun-
sel. At the outset of the hearing, counsel for the State generally
stated, “I have evidence in terms of both photos, the police
reports, and the video from the [child advocacy center] inter-
view.” The State then offered “Exhibits 4 through 19.” Counsel
for the State explained that Aaden’s counsel had previously
received copies of the State’s exhibits, which was not disputed
by Aaden’s counsel. The State did not offer any witnesses at
the hearing to support its evidence or to testify as to whether
Aaden’s case should be transferred.
The State’s exhibits contained what appear to be (1) undated
and unmarked photographs of scratches and bruises on various
parts of J.Z.’s body, (2) undated screenshots of text messages
apparently between Aaden and J.Z. where Aaden attempted to
coerce J.Z. into not talking to the authorities about what had
happened between them, (3) police reports, and (4) a video
recording of an interview of J.Z. conducted by the Family
Advocacy Network (FAN).
The photographs lacked any identifying labels other than
exhibit stickers. One of the police reports refers to J.Z.’s
sending an investigating officer photographs of injuries she
sustained. The screenshots of text messages show a few texts
where Aaden and J.Z. use each other’s names. Although the
screenshots indicate the phone numbers from which the text
messages were sent and received, Aaden’s and J.Z.’s phone
numbers were not established or identified.
In the FAN interview, J.Z. identified herself, discussed her
relationship with Aaden, and recounted the events that even-
tually led to Aaden’s arrest. J.Z. described the injuries she
sustained and the photographs she took of her injuries after

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IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
the fact. J.Z. described some of the text messages depicted
in the screenshots from exhibits 10 through 13, including
one specific text from Aaden saying, “[I] will get my fucking
hands on you . . . .”
Aaden’s counsel objected to the admission of the State’s
exhibits on due process grounds, authentication, foundation,
and the right to confrontation. Following the objections,
Aaden’s counsel and the juvenile court had a brief discus-
sion about the right to confrontation and due process and
how those rights relate to the court’s accepting evidence at
a juvenile transfer hearing. The discussion centered around
the ability of Aaden’s counsel to refute the State’s evidence.
The court expressed doubt that the Sixth Amendment right to
confrontation applies in a transfer hearing. Aaden’s counsel
responded that juveniles are entitled to due process of law in
juvenile court regardless of the applicability of the right to
confrontation. Aaden’s counsel also expressed concern that he
could not “cross examine anything about those photographs or
anything else that’s up there in your stack of exhibits.”
When the juvenile court pointed out that the formal rules
of evidence are not applicable in a juvenile transfer hearing,
Aaden’s counsel reiterated that there was still a right to due
process. The court responded that Aaden had notice, a hear-
ing, an attorney, the opportunity to present evidence, and the
opportunity to refute evidence. On the last point, Aaden’s
counsel again pointed out there was no opportunity to chal-
lenge the evidence by cross-examination and stated, “I think
that’s pretty critical.”
The juvenile court overruled the objections and received
exhibits 4 through 19, “unless counsel can provide me some
case law that says that the Court shouldn’t receive the exhib-
its for due process reasons.” However, the record does not
reflect that Aaden’s counsel submitted any such authority to
the court. Aaden’s counsel also did not call any witnesses
regarding the authenticity and substance of the State’s exhibits
and did not request a continuance in order to subpoena any

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
witnesses involved in preparing the reports or investigating
the case.
The allegations are set forth in (1) the police report detailing
a Kearney police officer’s interview with J.Z. on September 4,
2024; (2) the video recording of the FAN interview with J.Z.
on September 11; and (3) the police report summarizing the
FAN interview. We summarize these allegations as follows: On
August 17, Aaden, who was 16 years old at the time, was with
J.Z. at a party at a friend’s house south of Kearney and was
drinking alcohol. Aaden became upset with J.Z. and pushed
her against a wall and spit in her face. They moved into a bed-
room where Aaden continued to yell at J.Z. Aaden told J.Z. not
to tell anyone at the party what had happened.
The two continued to fight before deciding to leave the
party. When they decided to leave, Aaden again became angry
with J.Z. when she suggested she should drive because Aaden
had apparently consumed four shots of whiskey. Aaden then
hit her on the back of the head a few times. J.Z. got in the
backseat of the car, prompting Aaden to yell at her to get
into the passenger seat, which she apparently did. Aaden hit
J.Z. in the head again as they drove away. On the way home,
Aaden was driving erratically. When J.Z. sat on the floor of
the car out of fear, Aaden told her to sit in the seat or he
would crash the car.
When they were almost to Aaden’s house in Kearney, Aaden
asked J.Z. “why she was a whore” and hit her several more
times in the head and once across the face. It is unclear if this
happened while Aaden was still driving. When they arrived
at Aaden’s house, J.Z. told Aaden she was going home, but
Aaden refused to let her go. Aaden grabbed her by her neck to
get her out of the car.
Once outside of the car, J.Z. tried to run away, but Aaden
pulled her by her hair and punched her in the face. J.Z. tried
to get away again, but Aaden again pulled her by her hair,
punched her, and told her to get in the house. J.Z. said she
tried to get away several more times, with similar results. J.Z.

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320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
explained that one of the times she attempted to get away,
she saw a police cruiser. Aaden tackled her to the ground and
threatened to kill her if she got back up. Aaden grabbed an
area of J.Z.’s arm he knew contained her birth control device
in order to cause her pain and keep her quiet until the police
cruiser had passed.
After the police cruiser passed, the two ended up in a park
across the street from Aaden’s house. J.Z. again attempted to
scream. Every time she screamed, Aaden hit her, with one blow
resulting in a bloody nose.
The two began walking back to Aaden’s house, and Aaden
began to apologize. J.Z. again tried to run away, but Aaden tack-
led her. J.Z. believed this caused her to lose consciousness.
When she awoke, Aaden told her she could leave but could not
have her car keys or her phone. Apparently around this time,
she saw on her phone a notification from her video doorbell
camera that some people were at her house. This upset Aaden
because there were “guys” at her house.
J.Z. tried to run again, but Aaden pushed her up against the
garage door and told her to go inside. Inside his house, J.Z.
attempted to wash off the blood but could not wash off the
marks on her neck left by Aaden. She told Aaden she wanted to
sleep alone, but he pushed her onto the bed and started taking
her clothes off. She said no, but he continued. Aaden digitally
penetrated her vagina. J.Z. reported that she “had sex with
him to get him to stop.” When Aaden fell asleep, J.Z. went
and slept on the couch. The next day, Aaden would not let her
leave until midafternoon when he had to leave for work. J.Z.
reported that Aaden did not let her access her phone, other than
to use it to inform her mother where she was.
The next incident occurred 8 days later, when J.Z. was at
Aaden’s house. Aaden had again been drinking. J.Z. asked
Aaden if she was staying at his house, and he told her that she
was. J.Z. then took her clothes off, but Aaden did not. The two
laid together for a while before they started fighting. Aaden
asked J.Z. if she wanted to have sex, and she responded she

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
did not want to. Aaden then asked if J.Z. would perform oral
sex on him, and she responded she did not want to. Aaden then
told J.Z. she “was going to do one or the other.”
Aaden pulled out his penis, and J.Z. began performing oral
sex but stopped. Aaden again asked her if she wanted to have
sex, and she again said that she did not. Aaden then posi-
tioned J.Z. on her stomach and penetrated her vagina with his
penis. J.Z. stated that she told him multiple times to stop and
tried to move away from him, but he continued. At one point,
Aaden apologized for hurting her but did not stop. When this
ended, Aaden did not allow J.Z. to put her clothes back on.
He tried to rip her underwear off her when she attempted to
put it on.
The two got into a physical fight, and Aaden pushed her.
J.Z. told him she was leaving. Aaden tried to grab her by the
neck, and she screamed. When Aaden’s father, who was home,
inquired about what was happening, Aaden told him J.Z. was
“being a bitch” and was leaving. When she walked outside to
her car, he followed her and spit in her face.
After she left, Aaden “blew up” her phone. J.Z. stated
that she and Aaden had limited communication after the sec-
ond incident.
One of J.Z.’s friends reported the incidents to a school
counselor in early September 2024, leading to an investiga-
tion, Aaden’s arrest, and the filing of the juvenile petition
charging Aaden with the offenses listed above.
Aaden’s counsel called as a witness Tyler Mertens, a special-
ized juvenile probation officer assigned to Aaden, to support
Aaden’s position that transfer was not appropriate. Mertens
testified that Aaden was cooperative, polite, and respectful in
his interactions with Mertens. Mertens explained the process
of the intake summary and risk assessment inventory forms
he had completed for Aaden, which were identified as exhibit
3. Through Mertens, Aaden’s counsel offered and the court
accepted exhibit 3 into evidence.

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Nebraska Supreme Court Advance Sheets
320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
Mertens testified that Aaden had been held in a juvenile
detention center for about 3 weeks and had no negative
reports. During Aaden’s time at the juvenile detention center,
he underwent an evaluation consisting of both a drug and alco-
hol evaluation and a mental health evaluation. Aaden’s coun-
sel also offered exhibit 21, the evaluation report on Aaden,
which the court received over the State’s objection.
Mertens explained that, upon release from the juvenile
detention center, Aaden submitted to outpatient counseling,
was fitted with an electronic monitoring device, submitted
to drug testing, resumed attending school, was subjected
to an 8 p.m. curfew, and met with probation services regu-
larly. Mertens testified that Aaden tested positive for “THC”
on his first drug test but was negative on his subsequent
tests. Mertens testified that Aaden had been doing well, had
adjusted well to outpatient treatment services, and would ben-
efit from probation.
Counsel for the State then cross-examined Mertens. The
State’s cross-examination centered on Mertens’ lack of infor-
mation regarding the allegations contained in the police reports
and J.Z.’s FAN interview and how that lack of information
may have impacted his evaluation and testimony. On redirect
examination, Mertens explained that reading police reports is
not generally standard procedure in his work. Mertens further
explained that he was aware of the charges against Aaden
when he conducted his assessment.
At the end of the hearing, the juvenile court and the attor-
neys agreed to forgo oral arguments in favor of written argu-
ments. The record does not indicate whether written arguments
were received or considered by the court. The court then took
the matter under advisement.
Order on Transfer
The court issued a written order granting the State’s motion
to transfer Aaden’s case from the jurisdiction of the juvenile
court. The court examined the evidence presented by both

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IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
parties in the context of the factors enumerated in Neb. Rev.
Stat. § 43-276(1) (Cum. Supp. 2024).
Based on the evidence presented, the court found the first
factor, the type of treatment a juvenile would be most ame-
nable to, weighed in favor of the juvenile court’s retaining
jurisdiction. The court relied on exhibit 21—the evaluation
report—and the testimony of Mertens in making this finding.
The second factor, whether there was evidence that the
alleged offense included violence, was found to weigh heavily
in favor of transfer. The court relied on J.Z.’s descriptions of
the events in making this finding.
The court found the third factor, the motivation for the com-
mission of the offense, weighed heavily in favor of transfer.
The court described Aaden’s motivations as being sexual in
nature and exercising dominance and control over J.Z.
The court found the fourth factor, the age of a juvenile and
the ages and circumstances of others involved in the offense,
weighed heavily in favor of transfer. The court noted Aaden
was 16 years old at the time of the alleged offenses and was
17 years old at the time of the hearing. Because Aaden would
have fewer than 2 years of juvenile rehabilitative services, the
court found that to be an insufficient amount of time to treat
and supervise him. The court discredited Mertens’ testimony
on this point, stating that Mertens had limited information
regarding the allegations against Aaden.
The fifth factor, the previous criminal history of a juvenile,
weighed strongly in favor of retention in the juvenile court.
In making this finding, the court relied on the testimony of
Mertens that he was not aware of any prior juvenile adjudica-
tions of Aaden, as well as no evidence of previous convictions
having been presented.
The best interests of a juvenile, the sixth factor, weighed in
favor of retention in the juvenile court. Here again, the court
noted Aaden’s lack of prior court involvement. The court also
mentioned the potential repercussions of felony convictions on
Aaden’s life.

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320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
The court found the seventh factor, the consideration of
public safety, favored transfer. The court stated that the allega-
tions against Aaden were serious and involved violence. The
court disagreed with Mertens’ testimony that Aaden did not
present public safety concerns. The court relied on exhibits
10 through 13, which purported to show text messages where
Aaden threatened J.Z., as well as exhibit 3, which contained
the beliefs of a Kearney police officer regarding Aaden and an
intake screening risk assessment where Aaden scored a “12”—
meaning he needed “Secure Detention.”
The eighth factor, the consideration of a juvenile’s ability
to appreciate the nature and seriousness of his or her conduct,
was also found to favor transfer. The court again noted exhibit
13, where Aaden purportedly attempted to persuade J.Z. over
text message to not cooperate with police. Mertens’ testimony
that Aaden did not want to go back to detention and wished to
change was also considered for this factor.
The court found that the ninth factor, whether the best
interests of a juvenile and the security of the public may
require that the juvenile continue in secure detention or under
supervision for a period extending beyond his or her minority,
favored transfer. The court based this determination on Aaden’s
apparent attempts to manipulate J.Z., the violent nature of his
alleged crimes, and his age.
The 10th factor, whether a victim or juvenile agree to par-
ticipate in restorative justice, favored transfer because Aaden
was ordered to have no contact with J.Z. during the pendency
of the proceedings and she was unwilling to see Aaden.
Because no evidence was presented on the 11th factor,
whether there is a juvenile pretrial diversion program, the
court found it weighed in favor of retention in the juvenile
court. The same was true of the 12th factor, whether a juve-
nile has been convicted of or has acknowledged unauthorized
use or possession of a firearm, and the 13th factor, whether
a juvenile court order has been issued for the juvenile. With
regard to the 14th factor, whether a juvenile is a criminal

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320 Nebraska Reports
IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
street gang member, there was no evidence presented that
Aaden was a gang member. As such, the court found the 14th
factor favored retention.
Finally, the court found the 15th factor, such other matters as
the parties deem relevant to aid in the decision, favored trans-
fer. The court noted, under this catchall factor, that Aaden’s
parents told Mertens that Aaden “gets angry when he is treated
like a child because he thinks of himself as an adult.” The
court also highlighted that Aaden engaged in the “adult activ-
ity” of consuming alcohol, including during the alleged events
giving rise to this case.
Based on its consideration of these factors, the court found
the State had met its burden by a preponderance of the evi-
dence that Aaden’s case should be transferred to adult court
and, as such, granted the State’s motion to transfer. Aaden
appealed to the Court of Appeals.
Court of Appeals
The Court of Appeals consolidated Aaden’s seven assign-
ments of error into the following two assignments of error:
(1) the juvenile court violated his rights to confrontation and
due process by receiving evidence without requiring the State
to call any witnesses and (2) the juvenile court abused its
discretion in determining that his case should be transferred
to the adult docket of the county court. In a split opinion, the
Court of Appeals affirmed the transfer of Aaden’s case. 1
The Court of Appeals first took up Aaden’s arguments on
the juvenile court’s violations of his rights to confrontation and
due process by receiving all of the State’s evidence without
requiring the State to call any witnesses or otherwise authenti-
cate the evidence. The court noted that the right to confronta-
tion is generally not applicable to juvenile transfer hearings, as
held by this court in In re Interest of Brian B. et al. 2 As such,
1 See In re Interest of Aaden S., 33 Neb. App. 777, 25 N.W.3d 480 (2025).
2 See In re Interest of Brian B. et al., 268 Neb. 870, 689 N.W.2d 184 (2004).

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IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
the court turned its attention to whether Aaden’s due process
rights were violated.
The Court of Appeals discussed and relied on the U.S.
Supreme Court’s decision in Kent v. United States, 3 where the
Court laid out the three essential elements that must be pres-
ent in a juvenile transfer proceeding to satisfy due process: a
hearing, representation by counsel who is given an opportunity
to function, and a decision by the juvenile court containing
sufficient specificity to permit meaningful review. The Court
of Appeals noted that none of our case law has considered the
adequacy of the Kent due process requirements in juvenile
transfer proceedings. As a result, the Court of Appeals turned
to case law from other jurisdictions, which it found had largely
declined to afford juveniles with greater due process protec-
tions than those outlined in Kent, specifically as it related to
the right of confrontation.
The Court of Appeals then discussed our recent decision
in State v. Jeremiah T., 4 where the State similarly introduced
evidence at a juvenile transfer hearing without any sponsoring
witnesses to authenticate the evidence. The court acknowl-
edged that this practice was not raised in that appeal but found
it significant that we did not engage in a plain error analysis
disapproving of the practice.
The Court of Appeals found that Aaden’s due process rights
under Kent were satisfied, even if it agreed the State’s approach
“may not be the best practice in terms of creating a clear and
complete record for both the trial court and an appellate court
on review.” 5 The court found Aaden was given a hearing, was
represented by counsel at the hearing, and the juvenile court
issued a written opinion containing the reasons for granting the
3 See Kent v. United States, 383 U.S. 541, 86 S. Ct. 1045, 16 L. Ed. 2d 84
(1966).
4 State v. Jeremiah T., 319 Neb. 133, 21 N.W.3d 313 (2025).
5 See In re Interest of Aaden S., supra note 1, 33 Neb. App. at 790, 25
N.W.3d at 494.

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IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
State’s motion to transfer. The court stated that Aaden’s coun-
sel could have called any witness named in the police reports
or portrayed in the photographs or video recording received
by the juvenile court at the hearing. The Court of Appeals
determined Aaden’s due process and confrontation rights were
not violated by the State’s offering, and the juvenile court’s
receiving, exhibits without authentication and without support-
ing witness testimony.
The Court of Appeals then turned to the factors set forth
in § 43-276(1). It found the following factors favored trans-
fer of Aaden’s case to the adult court: (1) the violent and
sexual nature of the alleged crimes, (2) the motivation of the
alleged crimes, (3) Aaden’s age, (4) his ability to understand
the seriousness and wrongfulness of the alleged crimes, (5)
the perceived inability to rehabilitate him in the time before
he reaches the age of majority, (6) the security of the pub-
lic, (7) the inability to engage in restorative justice, and (8)
Aaden’s consideration of himself as an adult and engagement
in adult-like activities.
The Court of Appeals also found several factors that weighed
against transfer or on which no evidence was presented, which
must weigh against transfer: (1) Aaden’s best interests, (2) his
amenability to treatment, (3) his lack of a prior criminal his-
tory, (4) conviction for or unauthorized use of a firearm, (5)
involvement with a criminal street gang, (6) participation in
juvenile pretrial diversion program, and (7) no juvenile court
order issued for him under Neb. Rev. Stat. § 43-2,106.03
(Reissue 2016).
The Court of Appeals ultimately found the juvenile court
did not abuse its discretion by granting the State’s motion to
transfer. The Court of Appeals therefore affirmed the transfer
of Aaden’s case.
Chief Judge Riedmann authored a dissenting opinion that
took issue with the State’s presentation of evidence at Aaden’s
hearing, particularly with the lack of authentication or spon-
soring witness to identify the exhibits offered into evidence.

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IN RE INTEREST OF AADEN S.
Cite as 320 Neb. 785
While the rules of evidence do not apply in juvenile proceed-
ings, Chief Judge Riedmann cited In re Interest of Aaron
D., 6 where we explained that the basic requirements of due
process oblige a court to consider the type of evidence used
by the State in order to determine the weight to be given to
that evidence.
Chief Judge Riedmann pointed out that in all the cases
cited by the majority, the State had offered testimony to sup-
port its evidence, even if such testimony was hearsay. A com-
mon theme from other jurisdictions’ case law is whether the
evidence has indicia of trustworthiness or reliability, Chief
Judge Riedmann explained. Where, as here, the State offered
multiple exhibits without authentication, foundation, or any
sponsoring witness, Chief Judge Riedmann concluded that
Aaden’s hearing did not live up to the essentials of due pro-
cess and fair treatment as required by the U.S. Supreme Court
in Kent.
Turning to the juvenile court’s determination that Aaden’s
case should be transferred, Chief Judge Riedmann explained
she would have found the juvenile court abused its discre-
tion. The dissenting opinion took particular issue with the
juvenile court’s finding on the factor of whether Aaden could
be rehabilitated before reaching the age of majority. The
only evidence presented on this factor, Chief Judge Riedmann
explained, was the testimony of Mertens, who testified that
juvenile supervision would be best for Aaden. Furthermore,
Chief Judge Riedmann took issue with the juvenile court’s
perceived reliance on the seriousness-of-the-crimes factor in
determining Aaden’s case should be transferred, opining that
focusing on that factor improperly alleviated the State’s burden
imposed by statute.
Pursuant to Neb. Rev. Stat. § 24-1107 (Reissue 2016) and
Neb. Ct. R. App. P. § 2-102(F) (rev. 2022), Aaden petitioned
this court for further review, which we granted.
6 In re Interest of Aaron D., 269 Neb. 249, 691 N.W.2d 164 (2005).

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ASSIGNMENTS OF ERROR
On further review, Aaden assigns the Court of Appeals
erred (1) by finding Aaden’s rights to due process of law were
not violated by the juvenile court when it received materials
offered by the State as evidence without any identification or
authentication of those materials; (2) by not finding Aaden’s
right to counsel was violated due to his attorney’s inability
to contest the State’s evidence by cross-examination of wit-
nesses of the State, as those witnesses did not exist at the
transfer hearing; and (3) by affirming the juvenile court’s
finding that Aaden was not amenable to rehabilitative services
and doing so without having any evidence from the State to
support this conclusion.
STANDARD OF REVIEW
[1,2] The determination of whether the procedures afforded
to an individual comport with constitutional requirements for
due process presents a question of law. 7 An appellate court inde-
pendently reviews questions of law decided by a lower court. 8
[3] An appellate court reviews a juvenile court’s decision to
transfer a juvenile offender’s case to county court or district
court de novo on the record for an abuse of discretion. 9
ANALYSIS
Due Process of Law
As a threshold matter, we first address whether Aaden’s
juvenile transfer hearing measured up to the minimum protec-
tions of due process and fair treatment when the State offered,
and the court received, “Exhibits 4 through 19” into evidence
without calling any witnesses or authenticating the exhibits.
Aaden argues his due process rights were violated because
7 In re Interest of A.A. et al., 307 Neb. 817, 951 N.W.2d 144 (2020),
supplemented by 308 Neb. 749, 957 N.W.2d 138 (2021).
8 In re Interest of Jordon B., 316 Neb. 974, 7 N.W.3d 894 (2024).
9 In re Interest of Steven S., 299 Neb. 447, 908 N.W.2d 391 (2018).

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the evidence admitted in support of transfer lacked indicia
of reliability and provided no means for his counsel to cross-
examine or otherwise challenge the evidence against him.
What manner of evidence meets due process requirements in
a juvenile transfer hearing is a question of first impression for
this court.
[4-6] The U.S. and Nebraska Constitutions provide that no
person shall be deprived of life, liberty, or property without
due process of law. 10 The U.S. Supreme Court has said, and
we have reiterated, that “[d]ue process of law is the primary
and indispensable foundation of individual freedom. It is the
basic and essential term in the social compact which defines
the rights of the individual and delimits the powers which the
state may exercise.” 11 We have said the concept of due process
defies precise definition but embodies the notion of fundamen-
tal fairness. 12 Due process is flexible and calls for such proce-
dural protections as the particular situation demands. 13
We have recognized that juvenile court hearings must mea-
sure up to the essentials of due process and fair treatment. 14
Accordingly, the hearing to determine whether to deprive a
juvenile of the statutory protections of the juvenile court
must be “fundamentally fair” to satisfy minimum standards of
due process. 15
The U.S. Supreme Court has held that under the flex-
ible requirements of due process, what is fundamentally fair
10 In re Interest of Jordon B., supra note 8. See, also, U.S. Const. amend.
XIV, § 1; Neb. Const. art. I, § 3.
11 In re Gault, 387 U.S. 1, 20, 87 S. Ct. 1428, 18 L. Ed. 2d 527 (1967). See,
also, In re Interest of A.A. et al., supra note 7.
12 See, In re Interest of A.A. et al., supra note 7; D.W. v. A.G., 303 Neb. 42,
926 N.W.2d 651 (2019).
13 In re Interest of A.A. et al., supra note 7. See, also, Mathews v. Eldridge,
424 U.S. 319, 96 S. Ct. 893, 47 L. Ed. 2d 18 (1976).
14 See In re Interest of Leo L., 258 Neb. 877, 606 N.W.2d 783 (2000). See,
also, Neb. Rev. Stat. § 43-246(3) (Cum. Supp. 2024).
15 See Kent v. United States, supra note 3.

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depends on the nature of the private interest at stake and the
weight of that interest balanced against the opposing govern-
mental interests. 16 In Mathews v. Eldridge, 17 the U.S. Supreme
Court laid out three distinct factors to consider when identify-
ing the “specific dictates of due process.” First, consider the
private interest that will be affected by the State’s action. 18
Second, consider the “risk of an erroneous deprivation of such
interest through the procedures used, and the probable value,
if any, of additional or substitute procedural safeguards.” 19
Third, consider the State’s interest, “including the function
involved and . . . administrative burdens that the additional or
substitute procedural requirement would entail.” 20
[7,8] The purpose and statutory structure of the Nebraska
Juvenile Code recognizes the critical importance of both the
juvenile’s and the State’s interest in providing the protec-
tions of the juvenile court where appropriate. 21 A key goal
of the Nebraska Juvenile Code, concurrent with the respon-
sibility to “preserve the public peace and security,” is to
“remove juveniles who are within the Nebraska Juvenile Code
from the criminal justice system whenever possible and to
reduce the possibility of their committing future law violations
through the provision of social and rehabilitative services to
such juveniles and their families.” 22 We have long held that
the object of the juvenile code is corrective, to the end that the
child’s reformation be brought about, 23 and we have observed
that a juvenile proceeding is not a prosecution for a crime but
16 See Mathews v. Eldridge, supra note 13.
17 Id., 424 U.S. at 335.
18 See id.
19 Id.
20 Id.
21 See Neb. Rev. Stat. §§ 43-245 to 43-2,129 (Reissue 2016, Cum. Supp.
2024, & Supp. 2025).
22 See § 43-246.
23 In re Interest of Steven S., supra note 9.

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a special proceeding that serves as an ameliorative alternative
to a criminal prosecution. 24
The purpose of our statutes relating to youthful offenders
is the education, treatment, and rehabilitation of the child. 25
The juvenile code expounds upon these purposes at length,
and the codification of the relatively recent changes allocating
jurisdiction between juvenile and adult courts illustrates the
Legislature’s goal of favoring juvenile courts as forums for
criminal offenses committed by minor children. 26
If a case is transferred to the county or district court under
§ 43-274(5)(a), a juvenile has a right to appeal the decision to
the Court of Appeals. 27 Once a case is transferred to the county
or district court, a juvenile is subject to the full consequences
of the criminal justice system. 28
That said, we have also recognized the need for flexibility
in conducting the appropriate balancing test to ensure public
protection and societal security are weighed against the practi-
cal and nonproblematic rehabilitation of a juvenile. As we have
held in other contexts, a hearing of this nature should be flex-
ible enough to consider evidence that would not be admissible
in an adversary criminal trial. 29
The U.S. Supreme Court, in Kent, made it clear that the
question of whether to deprive a juvenile of the protections of
24 See id.
25 Id.
26 See id. (citing §§ 43-246 and 43-246.01).
27 See § 43-274(5)(b).
28 See § 43-274(5)(c). See, also, Neb. Rev. Stat. § 29-2204.02(6) (Reissue
2016) (“[i]f the defendant was under eighteen years of age at the time he
or she committed the crime for which he or she was convicted, the court
may, in its discretion, instead of imposing the penalty provided for the
crime, make such disposition of the defendant as the court deems proper
under the Nebraska Juvenile Code”).
29 State v. Johnson, 287 Neb. 190, 842 N.W.2d 63 (2014) (probation
revocation hearing).

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the juvenile court is a “‘critically important’” one, 30 while also
recognizing the need for flexibility in the proceedings. As a
result, the Court in Kent established certain minimal due pro-
cess protections for juvenile transfer hearings when it held that
the juvenile court in that case violated due process by trans-
ferring a juvenile’s case to adult court without a hearing and
upon an order that failed to give reasons sufficient to permit
meaningful review.
The U.S. Supreme Court explained that juvenile courts,
while given considerable latitude, should exercise “procedural
regularity sufficient in the particular circumstances to satisfy
the basic requirements of due process and fairness.” 31 And
“there is no place in our system of law for reaching a result
of such tremendous consequences without ceremony—without
hearing, without effective assistance of counsel, without a
statement of reasons.” 32
Although the State acts as parens patriae, rather than pros-
ecuting attorney and judge, “the admonition to function in a
‘parental’ relationship,” said the Court, “is not an invitation to
procedural arbitrariness.” 33 Indeed, the Court expressed con-
cern that in a transfer hearing, without procedural safeguards,
“the child receives the worst of both worlds: that [the child]
gets neither the protections afforded to adults nor the solicitous
care and regenerative treatment postulated for children.” 34
Elaborating on the necessary ceremony, the U.S. Supreme
Court held that the lower court must accompany its transfer
or waiver order with a “statement of the reasons” sufficient
to permit meaningful review. 35 And, before such order, there
30 Kent v. United States, supra note 3, 383 U.S. at 556.
31 Id., 383 U.S. at 553.
32 Id., 383 U.S. at 554.
33 Id., 383 U.S. at 555.
34 See id., 383 U.S. at 556.
35 Id., 383 U.S. at 561.

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must be a hearing that “measure[s] up to the essentials of due
process and fair treatment,” 36 even if it may be informal.
The Court focused at length on the right to counsel at such
a hearing. The Court held that the juvenile’s counsel must be
“given an opportunity to function.” 37 The Court characterized
the juvenile’s right to counsel in this context as “the essence
of justice,” which must include access to the government’s
evidence supporting trial of the juvenile in adult court. 38 The
Court said:
The 	right 	to 	representation 	by 	counsel 	is 	not 	a
formality. It is not a grudging gesture to a ritualistic
requirement. It is of the essence of justice. Appointment
of counsel without affording an opportunity for hearing
on a “critically important” decision is tantamount to
denial of counsel. 39
In Kent, the evidence on which the trial court based its transfer
decision was not made available to the juvenile’s counsel. The
Court thus explained that counsel’s opportunity to function is
not limited to presenting evidence or arguments to the court
on behalf of the child. 40 Counsel must also have the ability
to challenge the State’s evidence. The Court said, “[I]t is pre-
cisely the role of counsel to ‘denigrate’” the State’s evidence. 41
The Court accordingly held that the juvenile’s counsel was
entitled to see the juvenile’s social records that the court might
have relied upon in making its decision. 42 However, because
in the case before it there was no hearing at all, the Court did
not address the necessary qualities of the State’s evidence prof-
fered at a hearing or the manner of its admission.
36 Id., 383 U.S. at 562.
37 Id., 383 U.S. at 561.
38 Id.
39 Id.
40 See Kent v. United States, supra note 3.
41 Id., 383 U.S. at 563.
42 See Kent v. United States, supra note 3.

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Our juvenile transfer statutes codified the three Kent due
process requirements. First, Nebraska’s juvenile transfer stat-
utes require a hearing. Section 43-274(5)(a) provides, in rel-
evant part, “The juvenile court shall schedule a hearing on
such motion [to transfer] within fifteen days after the motion
is filed. The county attorney or city attorney has the burden by
a preponderance of the evidence to show why such proceeding
should be transferred.” 43 Second, Nebraska’s juvenile transfer
statutes require that the juvenile be represented by counsel.
Section 43-274(5)(a) continues: “The juvenile shall be rep-
resented by counsel at the hearing and may present the evi-
dence as to why the proceeding should be retained.” 44 Third,
Nebraska’s juvenile transfer statutes require the court to “set
forth findings for the reason for its decision.” 45 After consider-
ing “all the evidence and reasons presented by both parties,”
as stated in § 43-274(5)(a), “the juvenile court shall retain the
proceeding unless the court determines that a preponderance
of the evidence shows that the proceeding should be trans-
ferred to the county court or district court.”
[9] Our transfer statutes, however, do not address the quality
and manner of the admission of the evidence that must sup-
port, by such preponderance of the evidence, transfer to the
county or district court. In In re Interest of Aaron D., we said
that while the Nebraska Evidence Rules do not apply in juve-
nile proceedings, the basic requirements of due process oblige
a court to consider the type of evidence used by the State in
order to determine the weight to be given to that evidence. 46
In our recent juvenile transfer cases, the parties have not
raised due process issues, but we have discussed, at least
briefly, the presentation of evidence at the transfer hearings.
Summarized, our recent cases in which we have affirmed
43 See, also, Neb. Rev. Stat. § 29-1816(3)(a) (Cum. Supp. 2024).
44 See, also, id.
45 See § 43-274(5)(a). See, also, § 29-1816(3)(b).
46 In re Interest of Aaron D., supra note 6.

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juvenile transfer to the county or district court involve the
admission of self-authenticating evidence, in-court testimony
subject to cross-examination that supports documentary evi-
dence, or video evidence that supports documentary evidence.
For example, we have affirmed a case where the State has
offered self-authenticating exhibits in the form of a probable
cause affidavit and a certified copy of the juvenile’s juve-
nile court file. 47 We have also affirmed, or reversed on other
grounds, several cases where the State has offered sworn,
in-court testimony subject to cross-examination in addition to
documentary evidence. 48 This is true even when the in-court
testimony is not based on personal knowledge. 49
[10] The question remains whether the evidence in Aaden’s
hearing met these minimum due process standards. In answering
this question, we look, as we have in similar proceedings, 50 to
the Nebraska Evidence Rules as a guidepost. Though the rules
of evidence are not strictly applicable, 51 we have explained
they 	demonstrate 	“fairness” 	in 	various 	proceedings. 52 We
therefore consider Aaden’s objections to the State’s evidence
on authentication and foundation grounds—albeit under the
47 State v. Hunt, 299 Neb. 573, 909 N.W.2d 363 (2018).
48 See, e.g., State v. Stevens, 290 Neb. 460, 860 N.W.2d 717 (2015); State v.
Dominguez, 290 Neb. 477, 860 N.W.2d 732 (2015); State v. Tyler P., 299
Neb. 959, 911 N.W.2d 260 (2018); State v. Aldana Cardenas, 314 Neb.
544, 990 N.W.2d 915 (2023). See, also, State v. Esai P., 28 Neb. App. 226,
942 N.W.2d 416 (2020); State v. Lu, 33 Neb. App. 45, 10 N.W.3d 382
(2024).
49 See State v. Stevens, supra note 48 (testimony of probation officer’s
supervisor because probation officer was unavailable).
50 See, In re Interest of Floyd B., 254 Neb. 443, 577 N.W.2d 535 (1998)
(protective custody hearings pending adjudication); In re Interest of
Destiny A. et al., 274 Neb. 713, 742 N.W.2d 758 (2007) (termination
of parental rights hearings); State v. Johnson, supra note 29 (probation
revocation hearing); In re Interest of Ramon N., 18 Neb. App. 574, 789
N.W.2d 272 (2010) (dispositional review hearings).
51 See § 29-1816(3)(a).
52 See Neb. Rev. Stat. § 27-102 (Reissue 2016).

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wider umbrella of due process. An objection on the grounds
of foundation is a general objection that generally relies on
a specific ground, such as authentication. 53 Authentication is
governed by Neb. Rev. Stat. § 27-901 (Reissue 2016) of the
Nebraska Evidence Rules and does not impose a high hurdle
for admissibility. 54
[11] Authentication is often satisfied by testimony that a
matter is what it is claimed to be, but proper authentication
may also be attained by evidence of appearance, contents,
substance, internal patterns, or other distinctive characteristics,
taken in conjunction with circumstances, sufficient to support
a finding that the matter in question is what it is claimed to
be. 55 Some evidence is “self-authenticating” as provided by
Neb. Rev. Stat. § 27-902 (Cum. Supp. 2024) of the Nebraska
Evidence Rules and thus does not require extrinsic evidence of
authenticity to be admissible. Examples of self-authenticating
evidence include copies of official court records, 56 an acknowl-
edgment certified by a notary public such as an affidavit, 57 and
documents bearing an official government seal. 58 No self-
authenticating evidence pursuant to § 27-902 was offered in
this matter.
Under the particular facts of this case, we hold that Aaden’s
due process rights were not violated. Both Aaden and the State
were able to offer evidence and present arguments to the juve-
nile court. Aaden’s counsel had access to the State’s evidence
beforehand. And the State’s evidence was sufficiently reli-
able to be received and relied upon by the court. The video
recording of J.Z.’s FAN interview supports and corroborates
the information found in the police reports, the photographs,
53 State v. Harris, 263 Neb. 331, 640 N.W.2d 24 (2002).
54 See VKGS v. Planet Bingo, 309 Neb. 950, 962 N.W.2d 909 (2021).
55 See id.
56 See State v. Hall, 270 Neb. 669, 708 N.W.2d 209 (2005).
57 See State v. Jacobson, 273 Neb. 289, 728 N.W.2d 613 (2007).
58 See § 27-902(1).

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and the screenshots of text messages appearing to be between
Aaden and J.Z. J.Z.’s description of these documents provides
support for their reliability sufficient to support a finding that
they are what they purport to be. Notably, no one disputes
that J.Z.’s FAN interview is in fact a video recording of J.Z.
taken after the events at issue.
Therefore, the evidence offered and received at the transfer
hearing was sufficiently authenticated and therefore met the
minimum standards of due process. But we stress the blan-
ket offer of documentary evidence by the State at a juvenile
transfer hearing, without establishing foundation when such
evidence is not self-authenticating, is not a recommended
practice. Were it not for the video recording, the police reports,
photographs, and screenshots of text messages entered by the
State may not have been sufficient—standing on their own—to
support a finding of reliability.
While cross-examination of witnesses is a common way
of meaningfully contesting evidence, and we encourage the
State to provide a witness at a transfer hearing, a witness
is not absolutely required to satisfy due process in this con-
text. Aaden’s counsel was able to, and did, object to the
State’s evidence and make arguments as to why the juvenile
court should not have received the State’s evidence. Further,
Aaden’s counsel was given the opportunity to provide written
arguments to the court as to why the court should not receive
the exhibits for due process reasons, although it is unclear if
Aaden’s counsel did so. Aaden’s counsel could have requested
a continuance of the hearing in order to subpoena witnesses to
question at the hearing and contest the State’s evidence.
We 	caution 	the 	State 	that 	when 	it 	proffers 	non-self-
authenticating exhibits without any identification, foundation,
or sponsoring witness, the State runs the risk of failing to
meet its burden of proof by leaving the weight of the evidence
solely up to the judge’s consideration. Further, the State opens
itself up to due process challenges by not adequately estab-
lishing the reliability of its evidence at the transfer hearing.

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The State must show that the exhibits it offers are what they
purport to be. The burden is on the State to prove by a pre-
ponderance of the evidence that proceeding in the county or
district court is warranted.
Decision to Transfer Aaden’s
Case to Adult Court
We turn to Aaden’s argument that the Court of Appeals
erred by affirming the juvenile court’s finding that he was not
amenable to rehabilitative services without evidence from the
State to support this finding. Because Aaden was 16 years old
when he allegedly committed an offense punishable as a Class
II felony, the juvenile court had concurrent original jurisdic-
tion with the county court or district court. 59 Stated another
way, the action against Aaden could have been initiated either
in the juvenile court or in the county or district court. Our
statutory scheme allows the transfer of actions filed in the
juvenile court to an adult court and vice versa. 60
In making the “critically important” decision to transfer, the
juvenile court must consider 15 factors set forth in § 43-276(1):
(a) The type of treatment such juvenile would most
likely be amenable to; (b) whether there is evidence that
the alleged offense included violence; (c) the motivation
for the commission of the offense; (d) the age of the
juvenile and the ages and circumstances of any others
involved in the offense; (e) the previous history of the
juvenile, including whether he or she had been convicted
of any previous offenses or adjudicated in juvenile court;
(f) the best interests of the juvenile; (g) consideration of
public safety; (h) consideration of the juvenile’s ability
to appreciate the nature and seriousness of his or her
conduct; (i) whether the best interests of the juvenile and
the security of the public may require that the juvenile
59 See, § 43-246.01(3)(a)(iii); § 29-1816(1)(a)(ii).
60 See, § 43-274(5)(a); § 29-1816(2).

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continue in secure detention or under supervision for a
period extending beyond his or her minority and, if so,
the available alternatives best suited to this purpose; (j)
whether the victim or juvenile agree to participate in
restorative justice; (k) whether there is a juvenile pre-
trial diversion program established pursuant to sections
43-260.02 to 43-260.07; (l) whether the juvenile has
been convicted of or has acknowledged unauthorized use
or possession of a firearm; (m) whether a juvenile court
order has been issued for the juvenile pursuant to section
43-2,106.03; (n) whether the juvenile is a criminal street
gang member; and (o) such other matters as the parties
deem relevant to aid in the decision.
[12,13] In determining whether a case should be transferred
to criminal court, the juvenile court need not resolve every
factor against the juvenile, and there are no weighted factors
and no prescribed method by which more or less weight is
assigned to a specific factor. 61 Rather, the court must engage
in a balancing test by which public protection and societal
security are weighed against the practical and nonproblematic
rehabilitation of the juvenile. 62 Retention of the case in juve-
nile court is favored. The State has the burden to prove, by a
preponderance of the evidence, that a juvenile’s case should
transferred to adult court. 63
[14] We review the determination of whether a juvenile’s
case should be transferred de novo on the record for an abuse
of discretion. 64 An abuse of discretion occurs when a trial
court’s decision is based upon reasons that are untenable or
unreasonable or if its action is clearly against justice or con-
science, reason, and evidence. 65
61 See In re Interest of Steven S., supra note 9.
62 Id.
63 See § 43-274(5)(a).
64 See In re Interest of Steven S., supra note 9.
65 State v. Aldana Cardenas, supra note 48.

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The juvenile court found that the amenability to treatment
factor weighed in favor of retention at the juvenile court.
Nonetheless, it found that the remaining factors weighed in
favor of transferring Aaden’s case to the adult docket of the
county court. The juvenile court highlighted the violence and
motivation of the alleged crimes, Aaden’s age at the time of the
alleged crimes, and the consideration of public safety as factors
supporting transfer. The Court of Appeals engaged in a similar
exercise in affirming the juvenile court’s decision. 66
We agree with the Court of Appeals that the juvenile court’s
finding that Aaden’s case should be transferred is not untenable
or unreasonable. The juvenile court did not abuse its discretion
in ordering the transfer of Aaden’s case to the adult docket of
the county court.
CONCLUSION
Aaden’s due process rights were not violated, because his
counsel had access to the State’s evidence, his counsel was
given an opportunity to function at the transfer hearing, and the
State’s evidence bore indicia of reliability. Further, the juvenile
court’s decision to transfer Aaden’s case to the adult docket of
the county court was not an abuse of discretion.
Affirmed.
66 See In re Interest of Aaden S., supra note 1.