Justia Juvenile Law Opinion Summaries

The Supreme Court of Nevada addressed whether the provision under NRS 62C.200(1)(b) violates the separation of powers doctrine. This provision requires the district attorney's written approval before a juvenile court may dismiss a delinquency petition and refer a juvenile to informal supervision. The appellant, a juvenile referred to as I.S., was adjudicated a delinquent and placed on formal probation. I.S. appealed, arguing that the provision infringed upon the court's sentencing discretion, essentially granting an unconstitutional prosecutorial veto.The court concluded that I.S.'s appeal was not moot, despite the completion of his juvenile supervision, due to the presumption of collateral consequences of such an adjudication until the juvenile reaches age 18 and/or their juvenile record is sealed.On the main issue, the court held that the requirement under NRS 62C.200(1)(b) does not contravene the separation of powers doctrine. The court reasoned that this provision does not involve a sentencing decision. Rather, the court perceived it as akin to a charging decision, which is within the executive realm. The court further noted that, unlike adult courts, the juvenile court's authority is not derived from the constitution but is limited to the authority expressly prescribed to it by statute. Therefore, the court affirmed the district court's order, holding that the requirement for the district attorney's written approval before a juvenile court can dismiss a petition does not violate the separation of powers doctrine. View "In re I.S." on Justia Law

This case before the Indiana Supreme Court concerns a juvenile, A.W., who was adjudicated for possession of a machine gun and dangerous possession of a firearm. The court was asked to determine if these adjudications violated the principle of double jeopardy under Indiana law. A.W. asserted that he did not know the firearm he possessed had been modified to function as a machine gun.The court found that A.W.'s exclusive possession of the modified gun, along with his abrupt flight from police, supported the conclusion that he knowingly or intentionally possessed a machine gun. This satisfied the first part of the court's inquiry.On the issue of double jeopardy, the court noted that while the Indiana Constitution could apply in juvenile proceedings, it avoided deciding that issue. Instead, it focused on whether possession of a dangerous firearm is a lesser-included offense of possession of a machine gun under the test set out in the case Wadle v. State. The court found that it was, meaning A.W.'s adjudications for both offenses violated his rights under the principle of double jeopardy. Therefore, the court affirmed the finding that A.W. knowingly possessed a machine gun but reversed the adjudication that he committed dangerous possession of a firearm. View "A. W. v. State of Indiana" on Justia Law

In the case before the Supreme Court of the State of Kansas, the appellant, the State of Kansas, challenged a trial court's decision to suppress the confession of a minor identified as G.O. The trial court had determined that the confession was not voluntary, and therefore inadmissible. The Court of Appeals reversed the trial court's decision, prompting G.O. to appeal to the Supreme Court.The Supreme Court of Kansas considered whether G.O.'s waiver of his Fifth Amendment rights and his confession were voluntary. Under the Fifth Amendment, an individual has the right to remain silent and not incriminate themselves. This right can be waived if the individual voluntarily, knowingly, and intelligently chooses to speak. The court also examined whether G.O.’s Fourteenth Amendment rights were violated, which protect against involuntary confessions being used as evidence.The court found that while G.O. had been read his Miranda rights, the detective conducting the interview had made misleading statements that suggested G.O. was not in trouble and would not be arrested. The detective further suggested that the purpose of the interview was to help G.O.'s stepsister, which the court found was deceptive.The court also took into account G.O.’s age, his mental health issues, his lack of experience with law enforcement, and his educational struggles. The court concluded that these factors, in combination with the detective’s misleading statements, induced G.O. to confess involuntarily.Therefore, the court held that the trial court was correct in suppressing G.O.'s confession. It reversed the Court of Appeals' decision and affirmed the trial court's judgment. View "State v. G.O." on Justia Law

The Supreme Court of Pennsylvania considered whether a violation of a juvenile defendant's Fifth Amendment right is subject to appellate review for harmless error. The case involved Nazeer Taylor, who was charged with several serious felony offenses as a juvenile. The juvenile court transferred Taylor's case to adult criminal court, considering Taylor's refusal to admit guilt for his alleged offenses as a factor in its decision. The Supreme Court of Pennsylvania previously held that such consideration violated Taylor's Fifth Amendment right. In this appeal, the Supreme Court concluded that the violation constituted a structural error, not subject to a harmless error review. Given Taylor's current age of 27, neither the juvenile nor the adult criminal court had the statutory authority to conduct a new certification hearing. Consequently, the Supreme Court affirmed the order of the Superior Court reversing Taylor's conviction and discharging him. View "Commonwealth v. Taylor" on Justia Law

In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law

A jury found that Child-Respondent Antonio M. (Child) committed felony murder, attempted armed robbery, conspiracy to commit armed robbery, child abuse, and aggravated assault with a deadly weapon. The State charged Child as a participant in the fatal shooting of Fabian Lopez (Victim) at Frenger Park in Las Cruces. Uncontested evidence at Child’s adjudicatory hearing established that M.M. and two other participants killed Victim in his car in the course of a drug deal. During opening statements and closing arguments, defense counsel’s theory of the case was that the State could not present sufficient evidence of Child’s participation in the crime and that the robbery and resulting homicide were unplanned and unintended results of a simple drug purchase. Defense counsel did not challenge Child’s presence in the car that transported M.M. to and from the park. On appeal, Child challenged the admission of three in-court identifications under federal and state due process. The Court of Appeals reversed for plain error, finding that the in-court identifications were impermissibly suggestive and thereby violated Child’s due process right to a fair trial under the Fourteenth Amendment of the United States Constitution. The New Mexico Supreme Court determine that identity was not at issue regarding the testimony of the three relevant witnesses and thus that Child’s due process rights were not violated by the relevant in-court identifications. Accordingly, the Supreme Court reversed the Court of Appeals. View "New Mexico v. Antonio M." on Justia Law

The Louisiana Supreme Court granted the State’s application to review the court of appeal’s determination that the State failed to prove that 16-year-old D.W. was the person who entered a sheriff’s vehicle and stole firearms from inside it, and therefore that the evidence was insufficient to support the delinquency adjudication for burglary involving a firearm, La. R.S. 14:62, and theft of a firearm, La. R.S. 14:67.15. After reviewing the record, the Supreme Court found the State presented sufficient evidence that D.W. was a principal, in accordance with La. R.S. 14:24, to these felony-grade delinquent acts regardless of whether he personally entered the vehicle and took the firearms that were inside it himself. Therefore, the Court reversed the ruling of the court of appeal and reinstated the delinquency adjudication and dispositions imposed by the juvenile court, which were then affirmed. View "Louisiana in the interest of D.W." on Justia Law

While on juvenile parole related to a commitment to Oregon Youth Authority (OYA) in an earlier case, B.Y. was adjudicated to be within the jurisdiction of the juvenile court for interfering with a peace officer. Based on that conduct, the juvenile court imposed a new disposition, which also committed B.Y. to OYA custody, to commence at the conclusion of his existing commitment. B.Y. challenged that order, contending that the juvenile court lacked authority to impose consecutive commitments. A divided panel of the Court of Appeals agreed with B.Y. and reversed the juvenile court. The Oregon Supreme Court reversed the appellate court: “the statutory text neither expressly permits nor expressly prohibits the imposition of consecutive commitments. The statutory scheme does, however, confer broad authority on the juvenile court to fashion appropriate dispositions; that stands in contrast to the criminal code, where courts’ sentencing authority is more circumscribed. Given that contrast, the fact that the legislature did not explicitly provide for consecutive commitments in a circumstance such as this is unsurprising. In light of the wide latitude that the legislature has chosen to give juvenile courts, it is more reasonable to expect that if the legislature had intended to limit the juvenile court’s ability to impose consecutive commitments in this circumstance, the legislature would have indicated as much.” View "Oregon v. B. Y." on Justia Law