Justia Juvenile Law Opinion Summaries

A high school student, J.M., and her sisters initiated a physical altercation with another student at school, during which J.M. allegedly shoved a teacher into a wall and punched the student. The teacher later discovered he had a fractured rib, and the student sustained visible injuries. The school resource officer referred the incident to juvenile court, listing misdemeanor assault as the offense. A juvenile probation officer screened the case, classified it as a misdemeanor, and offered J.M. a nonjudicial adjustment agreement, which she accepted and began fulfilling by completing community service.After J.M. completed her community service but before restitution had been resolved, the State disagreed with the misdemeanor classification and filed a delinquency petition alleging three felony offenses: aggravated assault, assault, and riot, all stemming from the same incident. J.M. moved to dismiss the petition, arguing that prosecutors could not file charges after substantial compliance with the nonjudicial adjustment. The Third District Juvenile Court denied her motion, reasoning that no statute or rule precluded the State from filing a petition if it viewed the case as involving new allegations or a more serious offense.On interlocutory appeal, J.M. maintained that under Utah statutes governing nonjudicial adjustments, the probation officer’s eligibility determination should control and limit prosecutorial authority. The Supreme Court of the State of Utah reviewed the case and held that Utah’s Juvenile Code does not bar a prosecutor from filing a petition when a nonjudicial adjustment has been improperly offered for a disqualifying offense. The determination of whether an offense is disqualifying, such as a felony committed by a minor over age twelve, is an objective legal question not controlled by the referral or probation officer’s assessment. Because J.M. challenged only the prosecutor’s authority, not the felony characterization, the Supreme Court affirmed the juvenile court’s denial of the motion to dismiss. View "In re J.M." on Justia Law

A twelve-year-old child was charged with robbery and four related offenses following an incident in Baltimore City, where a victim’s purses were taken and liquid was thrown at her. Robbery, a crime of violence, anchored the juvenile court’s jurisdiction over the child under Maryland’s Juvenile Justice Reform Act, which restricts jurisdiction for children under thirteen except when charged with a violent crime or an act arising from the same incident. At the adjudicatory hearing, the magistrate found the child not involved in robbery but involved in misdemeanor theft, ruling that the timing of the force element was not established for robbery.After this finding, the child moved to dismiss the theft charge, arguing that jurisdiction was lost when the robbery count—the qualifying offense—was not sustained. The magistrate denied the motion, reasoning that jurisdiction attaches at filing and continues regardless of the adjudicatory outcome, following precedent from the Appellate Court of Maryland in In re J.B. The juvenile court proceeded to disposition, finding the child delinquent and imposing probation. The child’s exceptions and renewed motion to dismiss were also denied by a judge of the Circuit Court for Baltimore City.The Supreme Court of Maryland reviewed the case and held that jurisdiction, once attached by an allegation of a qualifying crime, continues until the child turns twenty-one unless terminated by a specific statutory mechanism. The court clarified that jurisdiction over offenses arising out of the same incident is derivative at filing but durable thereafter, unaffected by a not-sustained finding or dismissal of the anchoring violent charge. Additionally, the court rejected the child’s equal protection claim, finding a rational basis for treating children accused of violent crimes differently from those accused only of misdemeanors. The court affirmed the Circuit Court’s decision. View "In re: D.E." on Justia Law

A seventeen-year-old individual planned and carried out a violent attack resulting in the death of one person and serious injuries to two others. After purchasing a knife, he attended a dinner and sleepover with friends. Late at night, he attacked and fatally stabbed one victim, then proceeded to injure two others. The police apprehended him at the scene. He was charged with first-degree murder and two counts of attempted first-degree murder. The jury convicted him on all counts. Because he was a juvenile at the time, a separate sentencing hearing was held to consider mitigating factors under Florida law.The Circuit Court for Palm Beach County sentenced him to life without parole (LWOP) for each count, with the two attempted murder sentences running concurrently but consecutively to the murder sentence. The court announced that he would be eligible for judicial review after serving 25 years on the murder conviction, and again after serving another 25 years on the consecutive sentences for attempted murder. The defendant challenged his sentence, arguing that consecutive LWOP sentences for offenses committed in a single episode violated the Eighth Amendment, relying on Graham v. Florida. The Circuit Court denied relief, and on direct appeal, the Fourth District Court of Appeal upheld the sentences, holding that the structure provided a meaningful opportunity for release consistent with constitutional requirements. The Fourth District certified conflict with the Second District Court of Appeal’s decision in Mack v. State, which had found such consecutive sentences unconstitutional.The Supreme Court of Florida reviewed the case and held that the Eighth Amendment’s requirement of a “meaningful opportunity for release” from Graham v. Florida does not apply to juveniles convicted of homicide offenses. Instead, sentencing for juvenile homicide offenders is governed by Miller v. Alabama and Jones v. Mississippi, requiring individualized sentencing but permitting discretionary LWOP. The Court approved the Fourth District’s result, disapproved Mack, and upheld the sentences. View "Johnson v. State of Florida" on Justia Law

A mother surrendered her four-day-old twin sons at a hospital in Maryland under the Safe Haven Act, which allows parents to leave unharmed newborns at designated facilities within sixty days of birth without facing criminal or civil liability for the act of surrender. The mother left the infants with basic information but did not identify herself or provide for their ongoing care. The hospital notified the Anne Arundel County Department of Social Services, which took custody of the children and filed Child in Need of Assistance (CINA) petitions, seeking court intervention to ensure the children’s welfare. The mother was later identified and participated in the proceedings, explaining she acted out of concern for domestic violence.After de novo adjudicatory and disposition hearings in the Circuit Court for Anne Arundel County, sitting as a juvenile court, the court found that the mother’s actions constituted “neglect” under the CINA statute—specifically, that leaving the children without a legal custodian or provision for care placed them at a substantial risk of harm. The court denied the mother’s request to award custody to the father at that stage and committed the children to the Department’s custody. The mother appealed, and the Appellate Court of Maryland affirmed the juvenile court’s decision, reasoning that the absence of a legal custodian or care plan for the infants following surrender justified a finding of neglect.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s judgment. The Court held that a parent’s surrender of a newborn under the Safe Haven Act may constitute neglect under the CINA statute if the child is left without a legal custodian or provision for care, thus facing a substantial risk of harm. The Court also held that the Safe Haven Act’s grant of immunity from “civil liability” does not bar a CINA neglect finding, as such a finding is a non-punitive jurisdictional predicate necessary for state intervention and long-term care arrangements. View "In re: B.Cd. & B.Cb." on Justia Law

A defendant committed several serious offenses, including armed robbery, kidnapping, and multiple counts of sexual assault, when he was 14 years old. He pleaded guilty to four felonies and was sentenced at age 15 to a determinate prison term of 50 years. Years later, he filed a petition for recall and resentencing, arguing that his 50-year sentence, imposed for crimes committed as a juvenile, was the functional equivalent of a life without the possibility of parole (LWOP) sentence, making him eligible for relief under California Penal Code section 1170, subdivision (d)(1).The Superior Court of San Joaquin County denied the petition, finding that the defendant’s sentence was not an LWOP term but a determinate 50-year sentence. The court also reasoned that the relevant precedent did not apply because the defendant’s sentence was not the functional equivalent of LWOP. On appeal, the Attorney General agreed with the defendant that the sentence functioned as an LWOP, but the San Joaquin County District Attorney’s Office, appearing as amicus curiae, argued in favor of affirmance.The California Court of Appeal, Third Appellate District, reviewed the denial and examined whether the 50-year sentence, in light of developments in law and the enactment of Penal Code section 3051 (which provides for youth offender parole hearings), constituted the functional equivalent of LWOP. The court held that because Penal Code section 3051 made the defendant eligible for a parole hearing during his 15th year of incarceration, his sentence was not the functional equivalent of LWOP. The court rejected arguments that the sentence should be viewed as LWOP based solely on the original sentencing date, emphasizing the effect of section 3051. The judgment denying the petition for recall and resentencing was affirmed. View "People v. Garner" on Justia Law

A minor, RCR, was arrested and charged with several delinquent acts, including burglary and property destruction. At RCR’s initial hearing, he denied the allegations and requested counsel. With agreement from the State, the guardian ad litem, and RCR’s grandmother, the juvenile court ordered that RCR be placed in the custody of the Department of Family Services, with constructive placement at the Wyoming Boys’ School (WBS), pending further proceedings and prior to any adjudication of delinquency.After the court’s order, WBS refused to admit RCR without a formal adjudication of delinquency, citing statutory limitations. In response, the State sought to hold WBS in contempt. The juvenile court found WBS and its superintendent in contempt for not accepting RCR and allowed them to purge the contempt by admitting him. Subsequently, RCR admitted to the allegations and was adjudicated delinquent, after which the court again ordered completion of the WBS program. The Wyoming Attorney General’s Office appealed the contempt finding.The Supreme Court of the State of Wyoming reviewed the case. The Court first found the appeal technically moot because WBS had already complied with the contempt order and RCR had been adjudicated delinquent. However, the Court determined that exceptions to the mootness doctrine applied, including the matter’s public importance, the need to provide guidance, and the likelihood of recurrence. On the merits, the Court held that Wyoming law does not authorize the placement of alleged, but not yet adjudicated, delinquent juveniles at WBS for detention purposes. Only juveniles who have been adjudicated delinquent and otherwise qualify may be placed at WBS. The Court concluded that the juvenile court abused its discretion by holding WBS in contempt for not admitting RCR before adjudication. The decision of the juvenile court was reversed. View "In the Interest of RCR v. The State of Wyoming" on Justia Law

Two young children were the subject of a dependency proceeding after their father brandished a loaded handgun at a store employee and then fled police in a high-speed chase with one child in the car. The mother was present at the store but not directly involved in the incident. The Department of Children and Family Services alleged that the mother failed to protect the children, claiming she knew or should have known that the father possessed guns and allowed him unrestricted access to the children. The children were assessed to be well cared for in the mother’s home, and she denied knowledge of the father’s gun possession or drug use.The Superior Court of Los Angeles County, Juvenile Division, sustained allegations under Welfare and Institutions Code section 300, subdivisions (b)(1) and (j), declaring the children dependents of the court. The court found the mother’s denial of knowledge about the father’s gun possession not credible, based on prior incidents. It ordered the children to remain with the mother under Department supervision, with requirements for parenting classes and counseling, and prohibited the father from residing in the home. The mother timely appealed the jurisdiction findings and disposition order. While the appeal was pending, the juvenile court terminated jurisdiction, granting the mother sole legal and physical custody.The Court of Appeal of the State of California, Second Appellate District, Division Seven, reviewed the case. The court held that the appeal was moot because the jurisdiction finding as to the father was unchallenged and sufficient for jurisdiction, and the termination of dependency jurisdiction left no ongoing order affecting the mother’s rights. The court further determined that the mother’s conduct constituted “general neglect,” not “severe neglect,” so it was not reportable to the Child Abuse Central Index. The appeal was dismissed as moot. View "In re Landon M." on Justia Law

A newborn child was taken into state custody shortly after birth due to testing positive for addictive substances and requiring intensive medical care for withdrawal. The mother, who initially sought substance abuse treatment, was involuntarily discharged from her program for rule violations and aggression. After her discharge, she failed to participate in drug testing and further treatment, and disengaged from the Office of Children’s Services (OCS) for about a year. The child, considered an “Indian child” under federal law, was eventually placed in a foster home compliant with the Indian Child Welfare Act (ICWA). The father was largely absent and uninvolved. After nearly the child’s entire life in state custody, the agency petitioned to terminate parental rights.The Superior Court for the Third Judicial District in Anchorage held a termination trial. The OCS presented testimony from a substance abuse expert and a cultural expert from the child’s tribe, as required by ICWA. The cultural expert, who was a tribal elder and had relevant experience, testified generally about substance abuse, the importance of child safety, and the parents’ noncooperation, but provided little detail about the tribe’s specific cultural standards as they related to the mother’s conduct. The superior court found clear and convincing evidence of risk of harm to the child, relied on the expert testimony, and terminated the mother’s parental rights.On appeal, the Supreme Court of the State of Alaska found that, although the expert was qualified, his testimony did not sufficiently contextualize the mother’s conduct within the tribe’s social and cultural standards, as required by ICWA. The court held that such testimony must be specifically grounded in the facts of the case and provide meaningful cultural context. Because this standard was not met, the Supreme Court reversed the termination of parental rights and remanded for further proceedings. View "Viva G. v. State" on Justia Law

A juvenile in Orleans Parish was arrested and evidence was seized pursuant to warrants issued by a juvenile court hearing officer, rather than a judge or magistrate. The authority for the hearing officer to issue arrest and search warrants stemmed from local court rules adopted by the Orleans Parish Juvenile Court. The defendant challenged the validity of both the arrest and the search, arguing that the local rules conflicted with Louisiana statutes and the state constitution, which reserve warrant-issuing authority to judges and magistrates unless otherwise expressly permitted by law.The Criminal District Court for the Parish of Orleans denied the defendant’s motion to suppress the evidence obtained through the search and arrest warrants. The court held that the hearing officer acted with apparent authority under the court’s local rules, and that the warrants were valid at the time they were issued.Upon review, the Supreme Court of Louisiana addressed whether the local rules authorizing hearing officers to issue arrest and search warrants were valid under Louisiana law, and whether warrants already issued under those rules should be invalidated. The court held that the relevant provisions of the local rules conflicted with the Louisiana Children’s Code, the Louisiana Code of Criminal Procedure, and the Louisiana Constitution, and were therefore null and void. However, applying the de facto officer doctrine, the court found that the hearing officer’s acts were valid because the officer acted under color of authority before the rules were judicially declared invalid. Accordingly, the Supreme Court of Louisiana affirmed the trial court’s denial of the motion to suppress and remanded the case for further proceedings. View "STATE OF LOUISIANA VS. OWNEY" on Justia Law

Four minors were found jointly and severally liable for victim restitution totaling $15,850.54 after a juvenile court proceeding in Marin County. The restitution included amounts for lost wages and childcare expenses incurred by the victim’s mother due to the aftermath of an incident involving the victim, Jane Doe, and the four minors. Two of the minors, J.L. and O.V., challenged the portion of the restitution award intended to compensate childcare expenses, disputing the sufficiency of evidence for part of that amount. They further argued that, under a newly amended statute, their liability should be apportioned among the four co-offenders based on each minor’s share of responsibility, rather than joint and several liability.The Superior Court of Marin County, sitting as a juvenile court, held a contested hearing and found the People met their burden to establish the claimed restitution amount by a preponderance of the evidence. The juvenile court ordered J.L., O.V., and their co-offenders jointly and severally liable for the full amount. J.L. and O.V. appealed to the California Court of Appeal, First Appellate District, Division Two, arguing for a reduction in childcare expenses and for retroactive application of the amended Welfare and Institutions Code section 730.6, which eliminates joint and several liability for victim restitution and instead requires apportionment.The California Court of Appeal, First Appellate District, Division Two, reviewed the case on transfer from the California Supreme Court, which directed reconsideration in light of Ellingburg v. United States. The appellate court affirmed the juvenile court’s order. It held that substantial evidence supported the amount of restitution for childcare expenses. The court further held that the new law eliminating joint and several liability for victim restitution operates prospectively, not retroactively, and thus does not apply to J.L. and O.V. The judgment was affirmed. View "In re J.L." on Justia Law