The Arkansas Supreme Court has affirmed a lower court's decision to deny the transfer of Jonathan Rolfe's capital murder case from adult court to juvenile court, rejecting his constitutional challenge to the state's juvenile transfer procedures.
In a unanimous decision delivered Jan. 22, 2026, Associate Justice Shawn A. Womack wrote that the court rejected Rolfe's argument that Arkansas Code Annotated section 9-27-318 violates Amendment 80 of the state constitution and the separation-of-powers doctrine. The court cited its previous ruling in *C.B. v. State* (2012 Ark. 220), which addressed the same constitutional challenge.
Rolfe, who was 17 years old at the time of the alleged crimes, was charged in St. Francis County Circuit Court with three counts of capital murder and one count of felony theft. The charges stem from a Nov. 28, 2022, shooting incident in which three people were killed while they slept: Rolfe's mother, Shalonda Barton; her boyfriend, JaTerrence Wright; and Wright's 12-year-old sister. Authorities also allege that Rolfe took his mother's Cadillac.
The case originated when the State filed charges against Rolfe on Feb. 16, 2023, in adult court rather than juvenile court. Under Arkansas law, certain serious crimes involving juveniles can be prosecuted in adult court, particularly capital offenses.
Rolfe's defense team filed a motion to transfer the case to juvenile court, arguing that the statute governing such transfers was unconstitutional. Specifically, they contended that Arkansas Code section 9-27-318 violates the state's constitutional provisions regarding judicial authority and the separation of powers between different branches of government.
Circuit Court Judge Christopher W. Morledge denied the transfer motion, prompting Rolfe to file an interlocutory appeal with the Arkansas Supreme Court. In his appeal, Rolfe raised two primary arguments for reversal.
First, Rolfe argued that the transfer statute itself is unconstitutional under Amendment 80 of the Arkansas Constitution and the separation-of-powers doctrine. However, the Supreme Court noted that this exact constitutional challenge had been previously addressed and rejected in *C.B. v. State*, a 2012 decision where the court upheld the constitutionality of the juvenile transfer provisions.
Despite the existing precedent, Rolfe asked the court to revisit and reconsider its earlier ruling. The Supreme Court declined to do so, maintaining its position that the statute does not violate constitutional principles.
Second, Rolfe argued that the circuit court's order denying the transfer was deficient and that the court erred in declining to move his case to juvenile court. He maintained that the lower court failed to properly consider factors that would support a transfer to the juvenile system.
The Arkansas Supreme Court found that Rolfe's first argument regarding the statute's constitutionality was not properly preserved for appellate review, meaning it had not been adequately raised in the proceedings before the circuit court. This procedural issue prevented the high court from considering the constitutional challenge on its merits.
On the remaining preserved issues concerning the circuit court's handling of the transfer motion, the Supreme Court affirmed the lower court's decision. The court found that Judge Morledge had properly exercised his discretion in denying the motion to transfer the case to juvenile court.
The decision means that Rolfe will continue to face trial as an adult on the capital murder charges. If convicted of capital murder in adult court, he could face more severe penalties than would be available in the juvenile system, though his age at the time of the alleged crimes may affect potential sentencing options.
The case highlights ongoing tensions in the juvenile justice system regarding when serious crimes committed by minors should be prosecuted in adult court versus juvenile court. Arkansas law, like that of many states, provides mechanisms for transferring certain serious cases involving juveniles to adult court, particularly for violent felonies and capital offenses.
The Arkansas Supreme Court's affirmation of the circuit court's decision continues a trend of upholding prosecutorial discretion in charging juveniles as adults for serious violent crimes. The court's reliance on its 2012 precedent in *C.B. v. State* demonstrates the stability of Arkansas law regarding juvenile transfers and the constitutional authority of courts to make such determinations.
The case will now return to the St. Francis County Circuit Court, where Rolfe will face trial on the capital murder and theft charges. The prosecution will need to prove beyond a reasonable doubt that Rolfe committed the alleged crimes, while the defense will have the opportunity to challenge the evidence and present alternative theories or mitigating factors.
The tragic nature of the alleged crimes, involving the deaths of three family members including a child, underscores the serious nature of the charges and the court system's approach to handling violent crimes committed by juveniles.