He wasn't cleared. We have only seen 4 pages out of 14 or 16. The rest could have been an indictment of Burke, whether or not he was under the age of culpability. Or perhaps there was some other legal explanation. The indictments of Patsy and John made it EVERY clear that neither of them were charged with the murder of JonBenet, but that both of them had been involved in the coverup of her murder and had failed to protect her from a threat to her life. Since there was no one else in the house but the 3 of them, only the most obstinate person could still be arguing that Burke wasn't the perpetrator.