Justia Juvenile Law Opinion Summaries

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Sixteen-year-old defendant Adrian Vela and one of his fellow gang members confronted two suspected rival gang members. Vela’s accomplice pulled out a gun and shot the two victims, killing one of them. The prosecutor directly filed charges against Vela in “adult” criminal court. The jury found Vela guilty of murder, attempted murder, and found true the related firearm and gang allegations. Vela makes several interrelated claims of instructional error concerning accomplice liability. Vela also raises two constitutional challenges to his 72 years to life sentence. In the unpublished parts of its opinion, the Court of Appeal found the trial court committed no instructional errors. Further, Vela’s sentence did not violate either the equal protection clause or the Eighth Amendment. In the published portion of its opinion, the Court conditionally reversed the judgment: the electorate recently approved Proposition 57, which emphasized juvenile rehabilitation, prosecutors can no longer directly file charges against a minor in an “adult” criminal court. Vela was retroactively entitled to a transfer hearing because his case was not yet final on appeal. If, after conducting the hearing, the juvenile court judge determines that Vela’s case should be transferred to a court of criminal jurisdiction, then his convictions and sentence will be reinstated. But if the juvenile court determined that Vela was amenable to rehabilitation, and should remain within the juvenile justice system, then his convictions would be deemed juvenile adjudications. View "California v. Vela" on Justia Law

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B.M., seventeen years old, appealed from a juvenile court order declaring her a ward of the court and ordering her to serve 90 days in a juvenile justice facility. The juvenile court sustained a petition charging that B.M. committed a felony assault with a deadly weapon (a butter knife) in violation of Penal Code section 245, subdivision (a)(1). The court rejected B.M.'s claim that the juvenile court erroneously admitted statements she made to the police in violation of Miranda v. Arizona. The court concluded that the evidence was sufficient to support the finding that the butter knife she used was a deadly weapon. Consistent with an express direction from the California Supreme Court and time-honored rules on appeal, the court affirmed the trial court's factual finding that the instant butter knife was a deadly weapon because it was used in a manner capable of producing great bodily injury. The court disagreed with In re Brandon T. to the extent that it held to the contrary. Accordingly, the court affirmed the judgment. View "In re B.M." on Justia Law

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Edward, then age 14, grabbed a handbag from a 66-year-old woman and was apprehended by a police officer who saw him with the bag. A wardship petition alleged misdemeanor grand theft from the person (Pen. Code, 487(c)). Edward admitted the allegation. Edward was adjudged a ward of the court, placed on probation, and ordered to complete a six-month residential program at a youth rehabilitation facility, followed by a 90-day conditional release/parole period. The juvenile court probation conditions, including: “The minor shall not knowingly associate with anyone known to the minor to be a gang member or associated with a gang, or anyone who the [probation officer] informs the minor to be, a gang member or associated with a gang” and “[T]he minor is not to be on a school campus unless he’s enrolled.” The court of appeal struck the gang condition, upheld the campus condition, and remanded for specification of the maximum term of confinement and calculation of credit for time served. Without evidence of gang affiliation or association with gang members or risk of gang involvement on Edward’s part, the gang condition was not tailored to his future criminality, but the campus condition was not impermissibly vague. View "In re Edward B." on Justia Law

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Petitioner was convicted of second-degree murder and sentenced to 15 years to life in prison. The offense was committed in 1979, when petitioner was 17 years old. In 1982, at age 20, he pled guilty to assault with a deadly weapon on a peace officer and possession of a deadly weapon by a prisoner and was sentenced to four years, to be served consecutively to his life sentence. In 2015, after serving 35 years in prison, petitioner was found suitable for parole as a youthful offender under Penal Code 3051, effective in November 2015. Petitioner claimed that his release date was recalculated as November 2, 2017, based on a correction in his credit earning status. In June 2016, petitioner filed a habeas corpus petition challenging the legality of his continuing incarceration. The trial court denied relief, concluding that section 3051 does not exempt a youthful offender granted parole from serving a consecutive sentence for an offense committed in prison, citing section 1170.1(c), which provides that a consecutive sentence for an in-prison offense “shall commence from the time the person would otherwise have been released.” The court of appeal granted relief; section 1170.1(c), does not apply to petitioner’s case because his in-prison offense was committed before he was 23 years old, so he was entitled to release at the end of his indeterminate sentence pursuant to section 3051(d). View "In re Trejo" on Justia Law

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Seventeen-year-old Defendant was charged with two counts of sexual intercourse without consent. Defendant filed two motions to transfer each charge to Youth Court. The district court denied both transfer motions. Defendant ultimately pleaded guilty to one count of sexual intercourse without consent. Defendant was sentenced to fifty years in prison, with ten years suspended. The Supreme Court (1) affirmed the district court’s refusal to transfer the charges to Youth Court, holding that the district court did not err in denying the transfer motions; and (2) remanded for entry of an amended judgment and review of the sentence as provided by law, holding that the district court erred by not including the requirements found in Mont. Code Ann. 41-5-2503(1) in Defendant’s sentence. View "State v. Talksabout" on Justia Law

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Appellant challenged the district court's decision to grant the federal government's motion to dismiss the information filed against him in a juvenile delinquency proceeding without prejudice, and its decision to deny Appellant's motion to dismiss the information with prejudice. Appellant also challenged the district court's decision to authorize the federal government to disclose two confidential documents and Appellant's identity to third-parties, contending that the disclosed information should have been kept private. The court dismissed as interlocutory the appeal over the dismissal of the information without prejudice and the denial of Appellant's motion for dismissal with prejudice; affirmed the district court's authorization of disclosure of the confidential documents; and, because the court believed that the controversy surrounding the disclosure of Appellant's identity was moot on appeal, the court vacated the district court's decision to authorize disclosure of that information. View "United States v. Under Seal" on Justia Law

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Garcia died in August 2011 after receiving multiple stab wounds. Mendoza, Martell, and Ramirez were convicted following a joint trial, for second degree murder (Pen. Code 187, 189) with gang enhancements (section 186.22(b)) for killing Garcia. On rehearing, the court of appeal affirmed, rejecting arguments that the trial court erred by: excluding statements of a co-perpetrator; allowing the prosecutor to commit misconduct during the opening statement; admitting unduly prejudicial evidence of gang-related intimidation; failing to properly instruct the jury regarding voluntary intoxication, the required mental state for guilt as an aider and abettor, and the evidence necessary to prove the gang enhancement; allowing the prosecution to commit misconduct during its examination of a prosecution witness; admitting unduly prejudicial out-of-court statements; admitting unduly prejudicial evidence of prior convictions to prove a pattern of criminal gang activity; and allowing the gang expert to show unduly prejudicial slides in the slideshow that accompanied his expert testimony. The court also rejected a claim of ineffective assistance and a claim that Proposition 57, the Public Safety and Rehabilitation Act of 2016, should be applied retroactively to Ramirez because he was 16 years old at the time of the offense and his judgment was not final when voters approved Proposition 57. View "People v. Mendoza" on Justia Law

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A.T. is enrolled in high school. Her attendance is regular; she earns passing grades. She was riding with another minor in a car driven by her brother, also a minor with no delinquent history. Police stopped the car because its registration had expired. No one inside the vehicle possessed a valid driver’s license. Police arrested her brother for driving without a license. During an inventory search, officers found a handgun inside a backpack, in the trunk. A.T. waived her Miranda rights, and told police that her brother had found the gun that morning; they had agreed to put it in her backpack inside the car trunk to show to their father. The father of her brother’s girlfriend subsequently reported the gun was stolen from him. The juvenile court denied A.T.’s request to be released to her mother’s custody pending the disposition of charges. A.T. alleges the court improperly considered her refusal to accept a “package-deal” plea bargain and the suitability of the Vallejo neighborhood where her mother lives in an apartment, in deciding to detain her. The girl was released, upon pleading guilty to a misdemeanor, after serving 16 days in custody. A.T. moved to withdraw her plea. The court of appeal directed the lower court to decide that motion, considering that “[t]he Legislature has indicated that children should be released except under certain specific conditions of ‘immediate and urgent necessity’” and that the record reveals no such necessity. View "A.T. v. Superior Court" on Justia Law

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Defendant pleaded guilty to attempted murder. Defendant was sixteen years old at the time of the offense. Defendant was sentenced to twenty-five years in prison, including a mandatory minimum term of incarceration. Defendant was also ordered to pay $150,000 in mandatory restitution to the victim’s estate. Defendant was later resentenced and received immediate parole eligibility because the mandatory minimum period of incarceration had been deemed unconstitutional. The restitution was left in place. Defendant appealed, challenging the $150,000 in restitution to the victim’s estate. The Supreme Court affirmed, holding (1) the $150,000 mandatory restitution for juvenile homicide offenders is not facially unconstitutional; and (2) the $150,000 mandatory restitution was not unconstitutional as applied to Defendant. View "State v. Breeden" on Justia Law

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Defendant pleaded guilty to second-degree murder. Defendant was fifteen years old at the time of the offense. The district court sentenced Defendant to an indeterminate term of incarceration and ordered Defendant to pay $150,000 in mandatory restitution to the victim’s estate. Defendant appealed, challenging the $150,000 restitution award. The Supreme Court affirmed, holding (1) Iowa Code 901.5(14) does not authorize the district court to modify a restitution award otherwise required by Iowa Code 910.3B(1), and restitution under chapter 910 is mandatory; and (2) section 910.3B is not unconstitutional either as applied to all juvenile homicide offenders or as applied to Defendant. View "State v. Richardson" on Justia Law