M.J., a juvenile male who identifies as a female, was adjudicated delinquent for engaging in prostitution by solicitation. M.J. appealed the adjudication, saying there was insufficient evidence to support this adjudication. He also claimed that the State had the burden to prove that M.J. was not a victim of sex trafficking at the time of the alleged violation. In his appeal, M.J. claimed that the judge was biased against him because the judge did not use his preferred name or pronouns.
The appellate court found “this allegation of bias or prejudice to be subjective and conclusory. Although the juvenile judge’s refusal to acknowledge M.J.’s gender identity might be inconsiderate, the judge made no statements during that proceeding that would support a finding of actual bias or prejudice toward M.J. … Rather, the juvenile court stated a neutral, objective reason for denying the request and for using M.J.’s legal name during the proceedings.”
M.J. also claimed that the court “made a number of off-color jokes involving transgender females in open court,” but the appellate court concluded that M.J.’s assertion was not true, as the day this allegedly happened, court proceedings were not held.