Justia Juvenile Law Opinion Summaries

A police officer responded to a hotel where a mother, RN, was intoxicated and with her six-year-old son, JN. Due to her intoxication and the presence of a violent boyfriend at home, JN was taken into protective custody. RN tested positive for amphetamines and had a high blood alcohol content. The State filed a neglect petition, and JN was placed in foster care. The initial permanency plan was family reunification, and RN was required to follow a case plan that included maintaining sobriety and addressing her relationship with her boyfriend.The juvenile court held a shelter care hearing and placed JN in the State's temporary custody. RN made some progress but failed to maintain sobriety and continued her relationship with her boyfriend. The court extended the consent decree to allow more time for RN to comply with the case plan. However, RN missed drug tests, tested positive for methamphetamine, and failed to appear at a hearing, leading to the revocation of the consent decree and the adjudication of neglect. The permanency plan was updated to require inpatient drug treatment, but RN did not check into treatment until the day before the permanency hearing.The Wyoming Supreme Court previously reversed the juvenile court's order changing the permanency plan to adoption due to the lack of a reasonable efforts determination by the Department of Family Services (DFS). On remand, the juvenile court determined that DFS had made reasonable efforts based on the evidence from the original hearing and reaffirmed the change in the permanency plan. The court found that despite RN's bond with JN, her inability to maintain sobriety and provide a stable environment justified the change to adoption. The Wyoming Supreme Court affirmed the juvenile court's decision, finding sufficient evidence that the change was in JN's best interests. View "RN v. The State of Wyoming" on Justia Law

G.W. was convicted of simple assault in 2019 after allegedly grabbing the jacket of a Metropolitan Transit Police Department officer outside the Anacostia Metro Station. G.W. filed a notice of appeal, and the case was remanded to allow the trial court to set aside his conviction under the Youth Rehabilitation Act (YRA). Following the trial court's set-aside order and issuance of a new judgment and commitment order, G.W. filed a new notice of appeal, challenging his conviction.The Superior Court of the District of Columbia initially convicted G.W. of simple assault. G.W. timely filed a notice of appeal, and the case was stayed pending the outcome of the en banc decision in Perez Hernandez v. United States, which addressed the elements of an offensive touching assault. After the decision in Perez Hernandez, the stay was lifted, and G.W. sought an indicative ruling for a YRA set-aside. The trial court issued an indicative set-aside order, and the case was remanded. The trial court then issued a set-aside order and an amended judgment and commitment order, which G.W. appealed.The District of Columbia Court of Appeals reviewed the case and concluded that G.W.'s appeal was properly before the court. The court determined that the trial court had not applied the correct elements of an offensive touching assault as defined in Perez Hernandez. Specifically, the trial court did not consider whether G.W.'s actions would offend a person's reasonable sense of personal dignity and whether G.W. acted with the purpose of causing offense or knowing that his actions would cause offense. The court vacated the judgment and remanded the case for the trial court to make the necessary findings regarding G.W.'s mens rea and the nature of the touch. The court did not reach G.W.'s Rule 16 claim due to the decision to remand. View "G.W. v. United States" on Justia Law

Christopher Segerstrom was convicted of capital murder for the 1986 killing of a four-year-old and was initially sentenced to life imprisonment without parole. He was 15 years old at the time of the crime. Following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibits mandatory life without parole for juvenile offenders, Segerstrom's sentence was vacated and remanded for resentencing. The Washington County Circuit Court resentenced him to life with the possibility of parole after thirty years without a hearing, which was reversed by the Arkansas Supreme Court, mandating a hearing to consider mitigating factors.Upon remand, Segerstrom's fitness to proceed was contested. The circuit court initially found him unfit due to schizophrenia but later deemed him fit after a year of treatment, based on a forensic evaluation by Dr. Melissa Wright. Segerstrom's defense presented conflicting expert testimony, but the court credited Dr. Wright's findings. On the day of the resentencing hearing, Segerstrom's counsel requested a continuance, claiming he was unresponsive due to medication, which the court denied.During the resentencing, the court admitted prior testimony from Dr. Joseph Halka, who performed the autopsy, over Segerstrom's objection. The court also rejected a nonmodel jury instruction proposed by Segerstrom, which emphasized the differences between juvenile and adult offenders as per Miller. The jury ultimately sentenced Segerstrom to life imprisonment.The Arkansas Supreme Court affirmed the circuit court's decisions, holding that substantial evidence supported the finding of Segerstrom's fitness to proceed, the denial of the continuance was not an abuse of discretion, the admission of Dr. Halka's testimony was proper, and the rejection of the proposed jury instruction was appropriate given the sentencing options. View "SEGERSTROM V. STATE OF ARKANSAS" on Justia Law

In 2018 and 2019, a minor, J.S., committed a series of serious crimes, including seven street robberies, two burglaries, an attempted robbery resulting in murder, and the drugging and sexual assault of a 14-year-old girl. J.S. was 16 and 17 years old at the time of these offenses. The People filed an 18-count petition against J.S., including charges of murder, robbery, burglary, and sexual assault, and sought to transfer him to adult criminal court.The juvenile court in Ventura County conducted a transfer hearing and found that J.S. was not amenable to rehabilitation within the juvenile system's jurisdiction, which would expire when he turned 25. The court considered J.S.'s criminal sophistication, previous delinquent history, and the gravity of the offenses. Despite evidence of J.S.'s participation in rehabilitation programs and expert testimony suggesting potential for rehabilitation, the court concluded that the severity and premeditated nature of his crimes, along with his behavior in custody, indicated a need for prolonged treatment and supervision beyond the juvenile system's capacity.The California Court of Appeal, Second Appellate District, Division Six, reviewed the juvenile court's decision for abuse of discretion. The appellate court affirmed the transfer order, agreeing that substantial evidence supported the juvenile court's findings. The appellate court emphasized that it does not reweigh evidence or substitute its discretion for that of the trial court. The court found that the juvenile court had appropriately considered the statutory criteria and expert testimony, and its conclusion that J.S. was not amenable to rehabilitation within the juvenile system was supported by clear and convincing evidence. View "People v. J.S." on Justia Law

In two separate cases, mothers petitioned the Juvenile Court to involuntarily commit their children for inpatient care due to substance use disorders under Massachusetts General Laws c. 123, § 35. E.S. was committed for ninety days, and J.P. for thirty days, following hearings where family members and court clinicians testified about the juveniles' substance use and behaviors.In the case of E.S., the Bristol County Juvenile Court judge found clear and convincing evidence of a substance use disorder, citing E.S.'s history of alcohol and marijuana use, recent positive tests for fentanyl, and concerning behaviors such as stumbling and passing out. The judge also found a likelihood of serious harm due to the imminent risk posed by E.S.'s substance use and the lack of immediate outpatient care options. E.S.'s commitment was affirmed on appeal.For J.P., the Essex County Juvenile Court judge ordered commitment based on testimony about J.P.'s daily marijuana use, behavioral changes, and a single incident of driving under the influence. However, the court clinician did not find J.P. to be a danger to himself or others. On appeal, the Supreme Judicial Court found the evidence insufficient to support a likelihood of serious harm, noting the lack of clear evidence of imminent risk. J.P.'s commitment order was reversed.The Supreme Judicial Court of Massachusetts held that a finding of a substance use disorder under § 35 must be supported by clinical evidence to comply with substantive due process. The court affirmed E.S.'s commitment but reversed and vacated J.P.'s commitment, remanding the case for entry of an order consistent with its opinion. View "In the Matter of J.P." on Justia Law

Elizabeth T. was taking her three children to see their father when she fell on a bus after consuming alcohol. An anonymous caller reported her to the Los Angeles County Department of Children and Family Services (DCFS), alleging she was intoxicated and her children were neglected. Elizabeth denied being heavily intoxicated and claimed her children were well cared for. DCFS filed a petition under Welfare and Institutions Code section 300, subdivision (b), alleging Elizabeth's substance abuse posed a risk to her children.The Superior Court of Los Angeles County sustained the petition, citing a prior sustained allegation of substance abuse from 2018. The court ordered informal supervision under section 360, subdivision (b). Elizabeth appealed, arguing that one incident of alcohol abuse did not support the finding that she posed a risk to her children at the time of the jurisdiction hearing.The California Court of Appeal, Second Appellate District, reviewed the case. The court found that the evidence of the bus incident, along with the four-year-old allegation, did not support the finding that Elizabeth's conduct created a substantial risk of serious physical harm or illness to her children. The court noted that Elizabeth had cooperated with DCFS, submitted to drug and alcohol testing, and her children were healthy and well cared for. The court concluded that there was no substantial evidence of a current risk to the children and reversed the juvenile court's jurisdiction findings and disposition orders. View "In re Gilberto G." on Justia Law

A minor, V., was removed from her mother’s care at birth due to the mother’s drug abuse. V. and her half-brother, N., were initially placed together with a relative, but N. was later moved to his non-offending father’s custody. V. was placed with her aunt, who became her legal guardian in 2019. The aunt sought to adopt V. in 2022, but the mother opposed the termination of her parental rights, citing the parental relationship exception to adoption.The Superior Court of Los Angeles County found that the mother did not meet the burden to demonstrate the parental relationship exception. However, the court, without input from the parties, applied the sibling relationship exception, concluding that adoption would not be in V.’s best interest due to her bond with N. The court selected legal guardianship as the permanent plan for V. Both the Los Angeles County Department of Children and Family Services (DCFS) and V. appealed.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the juvenile court erred by sua sponte applying the sibling relationship exception without any party asserting it and by relieving the mother of her burden to prove an exception to adoption. The appellate court found that substantial evidence did not support the juvenile court’s finding that the sibling relationship exception applied, as V. and N. had limited shared experiences and their relationship would likely continue even if V. were adopted. The appellate court reversed the juvenile court’s orders and directed it to enter a new order selecting adoption as the permanent plan for V. View "In re V.S." on Justia Law

In this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law

A minor child, Rene V., was removed from the custody of his legal guardian, Dora V., by the Los Angeles County Department of Children and Family Services (DCFS) due to allegations of abuse and neglect. Dora was appointed as Rene's legal guardian by the juvenile court. After Rene's removal, the juvenile court ordered family reunification services for Dora, including visitation. However, Rene refused to participate in overnight visits and eventually refused all visitation with Dora.The juvenile court sustained the DCFS's petition and ordered family reunification services for Dora. At an 18-month review hearing, the court terminated Dora's reunification services and set a selection and implementation hearing. Dora filed a petition for writ of mandate, arguing that the juvenile court erred by allowing Rene to refuse visits and that no substantial evidence supported the finding that she received reasonable reunification services. The court issued an order to show cause but denied Dora's request to stay the section 366.26 hearing.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that legal guardians appointed by the juvenile court are not entitled to a presumption of reunification services, unlike those appointed under the Probate Code. The court found that the juvenile court did not abuse its discretion in denying additional reunification services to Dora. The court emphasized that the statutory scheme for dependency guardianships does not mandate reunification services and that the juvenile court's decision was in Rene's best interests. Consequently, the petition for writ of mandate was denied. View "Dora V. v. Super. Ct." on Justia Law

Fifteen-year-old Bjorn Harris was arrested on April 30, 2023, for murder and other charges related to the shooting death of Jaylan Major. He was detained at the Regional Metro Youth Detention Facility. On May 5, 2023, the Superior Court of Fulton County found probable cause for the charges, appointed counsel for Harris, and denied bond. Harris was indicted on July 28, 2023, for voluntary manslaughter, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony. On November 16, 2023, he was reindicted for murder, felony murder, and additional charges. The initial indictment was nolle prossed on November 21, 2023.Harris filed a motion on December 1, 2023, to transfer his case to juvenile court, arguing that the State failed to indict him within 180 days as required by OCGA § 17-7-50.1. The Superior Court held a hearing on December 7, 2023, and granted the motion on December 11, 2023, relying on the Court of Appeals' decision in State v. Armendariz. The court concluded that the reindictment outside the 180-day period necessitated the transfer to juvenile court.The Supreme Court of Georgia reviewed the case and reversed the Superior Court's decision. The Supreme Court held that OCGA § 17-7-50.1 requires a grand jury to return a true bill of indictment within 180 days of detention, which was met with the July 2023 indictment. The statute does not prohibit reindictment outside the 180-day period. Therefore, the Superior Court retained jurisdiction, and the transfer to juvenile court was not authorized. The Supreme Court clarified that the timely return of a true bill on any charge within the superior court's jurisdiction suffices to retain jurisdiction, regardless of subsequent reindictments. View "THE STATE v. HARRIS" on Justia Law