Justia Juvenile Law Opinion Summaries

The case concerns a youth, W.D., who was adjudicated as a delinquent in the First Judicial District Youth Court, Lewis and Clark County, after admitting to sexual assault in 2019. Following unsuccessful residential placements and a probation revocation, the Youth Court committed W.D. to the Department of Corrections (DOC) until age 18, with probationary conditions to remain until age 21 and deferred sex offender registration. Upon release from Pine Hills at age 18, W.D. returned to community supervision. The State later sought a hearing under § 41-5-208, MCA, to transfer jurisdiction to the district court and supervisory responsibility to adult probation, alleging multiple violations of the previous order but without filing a formal petition to revoke probation under § 41-5-1431, MCA.After the hearing, the Youth Court found transfer appropriate and ordered jurisdiction and supervisory responsibility transferred to the district court and adult probation until W.D. reached age 25. Additionally, the Youth Court committed W.D. to the DOC until age 25, recommended placement at the Missoula Assessment and Sanction Center for sex-offender treatment, and required him to register as a Tier II sexual offender during non-incarceration periods. W.D. appealed, arguing that the Youth Court exceeded its authority under § 41-5-208, MCA, by imposing new custodial and registration requirements without proper procedural protections.The Supreme Court of the State of Montana reviewed the Youth Court’s interpretation and application of the Montana Youth Court Act de novo. It held that § 41-5-208, MCA, only authorizes transfer of jurisdiction and supervisory responsibility and does not permit a youth court to impose a new custodial disposition or additional conditions, such as sex-offender registration, at a transfer hearing without following procedures for probation revocation under § 41-5-1431, MCA. The Supreme Court reversed the Youth Court’s order and remanded for amendment to strike the added DOC commitment, extended supervision, and registration requirement. View "In re W.D." on Justia Law

Miguel J., a young child, was present during multiple incidents of domestic violence between his parents. On March 10, 2024, Miguel’s father, while intoxicated and in a physical altercation with the mother, accidentally struck Miguel in the face as the mother held him. Miguel was not injured, but the mother sustained injuries including a lacerated lip and cut foot. Mother reported prior incidents where the father struck her while she was pregnant and while breastfeeding Miguel. Both parents later gave conflicting accounts to social workers, sometimes recanting earlier statements about the violence and whether Miguel was struck.The Los Angeles County Department of Children and Family Services filed a dependency petition under Welfare and Institutions Code section 300, subdivisions (a) and (b), alleging risk of harm to Miguel due to the parents’ violent altercations and substance abuse by the father. The Superior Court of Los Angeles County held hearings, found the mother’s initial accounts credible, and sustained the petition under both subdivisions (a) and (b), declaring Miguel a dependent of the court and removing him from the father’s custody. The court ordered services for both parents, including domestic violence programs and monitored visitation for the father.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that section 300, subdivision (a), applies to domestic violence between parents when one parent intentionally commits violence in the child’s presence, and the child is either harmed or at risk of serious harm. The evidence supported jurisdiction under both subdivisions, and the petition language reflected the court’s factual findings. The removal order was also affirmed, as substantial evidence indicated Miguel faced a substantial risk if returned to the father. The jurisdictional findings and dispositional order were affirmed. View "In re Miguel J." on Justia Law

The case centers on a juvenile, John Doe, who was charged by the government with two counts of violating the Federal Juvenile Delinquency Act by possessing a handgun in violation of 18 U.S.C. § 922(x)(2) on two separate occasions. Section 922(x)(2) prohibits juveniles from knowingly possessing a handgun or handgun ammunition, with certain exceptions outlined in the statute. Doe challenged the charges, asserting that the statute exceeded Congress’s authority under the Commerce Clause and violated the Second Amendment, though he ultimately appealed only the Commerce Clause issue.The United States District Court denied Doe’s motion to dismiss the information, finding that Congress had the power to enact § 922(x)(2) under the Commerce Clause. Doe admitted delinquency to one count, was sentenced to juvenile probation until his 21st birthday, and subsequently appealed the district court’s Commerce Clause ruling to the United States Court of Appeals for the Tenth Circuit.The United States Court of Appeals for the Tenth Circuit reviewed the constitutionality of § 922(x)(2) de novo. The court held that Congress had a rational basis to conclude that regulating juvenile handgun possession was an essential part of a comprehensive regulatory scheme aimed at the interstate handgun market. The court determined that Congress could rationally conclude that the regulatory scheme would be substantially undercut if § 922(x)(2) were removed, and that such regulation directly and substantially affects interstate commerce. Accordingly, the Tenth Circuit affirmed the district court’s ruling, upholding Congress’s authority to enact § 922(x)(2) under the Commerce Clause. View "United States v. Doe" on Justia Law

A 16-year-old defendant shot and killed a 17-year-old in what appeared to be a gang-related incident. The defendant, riding in the backseat of a car, observed the victim wearing a rival gang’s T-shirt, exited the vehicle, and shot the victim five times. Charged with first-degree murder and felony-firearm, the jury convicted him of the lesser included offense of second-degree murder and felony-firearm. The trial court sentenced him as an adult to 50 to 75 years’ imprisonment for second-degree murder, consecutive to two years for felony-firearm, exceeding the advisory sentencing guidelines recommending 12 to 25 years or parolable life.On direct appeal, the Michigan Court of Appeals affirmed the conviction and sentence, finding no disproportionality under People v Milbourn. The Michigan Supreme Court denied leave to appeal. Decades later, the defendant filed a motion for relief from judgment, arguing his sentence was unconstitutional and disproportionate in light of Miller v Alabama and related cases. The Wayne Circuit Court denied the motion, as did the Court of Appeals. The Supreme Court remanded for reconsideration in light of People v Stovall and People v Boykin, which addressed youth sentencing.The Michigan Supreme Court held that a sentence of 50 to 75 years’ imprisonment for second-degree murder committed by a youthful offender violates the prohibition on cruel or unusual punishment under the state constitution and applies retroactively to cases on collateral review. The Court found that all Bullock factors supported this conclusion, noting that such a sentence is harsher than those imposed for first-degree murder on youths and fails to advance rehabilitation. The Court affirmed the Court of Appeals’ reversal of the trial court’s denial of relief, vacated the sentence, and remanded for resentencing, while vacating portions of the Court of Appeals’ opinion addressing Milbourn and Boykin. View "People Of Michigan v. Eads" on Justia Law

A defendant, who was 15 years old at the time of the offense, was convicted in 1988 of first-degree felony murder, armed robbery, and felony-firearm following a bench trial. He received a sentence of life without parole for the murder conviction. After the United States Supreme Court decided in *Miller v. Alabama* that mandatory life without parole sentences for juveniles are unconstitutional, and in *Montgomery v. Louisiana* that this rule applies retroactively, the prosecution moved to reimpose the defendant’s life without parole sentence under Michigan law. At his resentencing hearing, the defendant presented expert psychological evidence suggesting his capacity for rehabilitation, while the prosecution presented no witnesses. The trial court reimposed the life without parole sentence, stating the prosecution did not bear the burden of proof.The Michigan Court of Appeals later vacated the amended sentence after the Michigan Supreme Court held in *People v. Taylor* that the prosecution bears the burden of proof at such hearings. On remand, the prosecution requested that the defendant be compelled to undergo a psychological evaluation by its expert or, alternatively, that the defense’s psychological evidence be excluded. The trial court granted this request, and the Court of Appeals affirmed that decision.The Michigan Supreme Court held that if a defendant intends to introduce expert psychological evidence at a Miller resentencing hearing, the trial court may require the defendant to submit to a psychological examination by a prosecution expert, consistent with the constitutional right against self-incrimination. However, evidence from this compelled examination is admissible only as rebuttal and not during the prosecution's case-in-chief. The court also clarified that the second Miller hearing is a new proceeding and vacated any order incorporating the record from the prior hearing. The case was remanded to the trial court for proceedings consistent with these rulings. View "People v. Black" on Justia Law

After her 18th birthday, a young woman with severe disabilities, requiring 24-hour care and living in a subacute facility since infancy, was placed under extended foster care as a nonminor dependent. She had no family contact and lacked the mental capacity to make independent decisions. Her county child welfare agency regularly submitted reports and transitional independent living plans, documenting her progress and confirming her continued eligibility for extended foster care. The agency recommended continued jurisdiction, especially while her application for supplemental security income was pending, and later reported plans for her care to be managed by a regional center as she approached adulthood.The Superior Court of San Bernardino County repeatedly found that she was making satisfactory progress toward her care goals and met the requirements to remain a nonminor dependent. The court ordered continued jurisdiction until, in a subsequent review, the agency recommended dismissal, citing the transition of her care to the regional center. Following a contested hearing, despite arguments from her counsel and guardian ad litem for continued court oversight, the juvenile court terminated jurisdiction. The court reasoned that ongoing jurisdiction was not in her best interest, finding no further benefit to her from county oversight given her new care arrangements.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the appeal. The court held that the juvenile court applied the wrong legal standard by terminating jurisdiction based on a subjective best interest determination instead of the statutory criteria. Under section 391, jurisdiction over a nonminor dependent may only be terminated if the nonminor does not wish to remain under jurisdiction, is not participating in a reasonable transitional plan, or cannot be located. None of these circumstances applied. The appellate court therefore reversed the termination order and directed reinstatement of jurisdiction. View "In re Violet S." on Justia Law

The case involved allegations that a father sexually abused his minor daughter, H., over a period of years, and that he also abused her friends and provided them with intoxicating substances when they visited his apartment. The evidence included testimony from H., two of her friends (A.L. and A.B.), and a social worker, describing sexual misconduct and the provision of alcohol, marijuana, and vapes to the minors. The prosecution also introduced evidence that the father showed pornographic material to the girls. The defense denied all allegations and sought to present character witnesses to attest to his honesty.In the Circuit Court for St. Mary’s County, the defendant was convicted by a jury of sexual abuse of a minor, second-degree rape, and third-degree sexual offense. The court admitted the testimony of H.’s friends regarding other alleged abuses and denied the defendant’s motion to exclude this evidence under Maryland Rule 5-404(b). The court also refused to allow the defendant’s character witnesses to testify as to his honesty. Additionally, during cross-examination, the prosecutor asked the defendant why his daughter would lie about the allegations, to which the defense objected.The Appellate Court of Maryland affirmed the convictions, holding that the evidence of other bad acts was admissible to explain the victim’s delayed reporting and to corroborate her testimony, and that the exclusion of character witnesses was proper.The Supreme Court of Maryland affirmed the judgment. It held that the trial court did not err in admitting the other bad acts evidence under the “common scheme or plan” exception to Rule 5-404(b), as the acts were sufficiently connected to show a general plan of abuse involving the daughter and her friends. The Court further held that the prosecutor’s “why-would-she-lie” question was improper but found the error harmless beyond a reasonable doubt. Finally, it concluded that the trial court properly excluded the defendant’s character evidence for honesty, as the charges were not veracity-impeaching offenses and the defense’s proffers lacked specificity. View "Spicuzza v. State" on Justia Law

The defendant, after joining a gang at age 14, participated in a drive-by shooting in Iowa that resulted in the death of a bystander. He was convicted by a state jury of first-degree murder, but the conviction was reversed on appeal. He subsequently pleaded guilty to voluntary manslaughter and related charges and was sentenced to up to 25 years in state prison. Following his release in 2014, he was convicted of being a felon in possession of a firearm and later, after further criminal activity including high-speed chases and renewed gang involvement, conspired to distribute cocaine and participated in a shooting incident in 2020. Surveillance footage captured him firing a weapon, and he was later charged federally with RICO conspiracy and felon-in-possession offenses.The United States District Court for the Southern District of Iowa denied the defendant’s pretrial motions to dismiss the indictment. He had argued that the inclusion of his juvenile conduct in the RICO charge violated the Juvenile Delinquency Act (JDA), and challenged the constitutionality of the felon-in-possession statute under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The district court rejected both arguments, and the defendant entered a conditional guilty plea, preserving his right to appeal the denial of his motions.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s rulings de novo. It held that post-majority ratification of a conspiracy allows pre-majority conduct to be considered as part of a federal RICO prosecution, making the JDA inapplicable in this context. The court also held that circuit precedent foreclosed the defendant’s Bruen-based challenge to the felon-in-possession statute. The Eighth Circuit affirmed the district court’s denial of the motions to dismiss. View "United States v. Bogan" on Justia Law

Two children were removed from their home after the New Hampshire Division for Children, Youth and Families (DCYF) received reports of neglect and abuse by their legal guardians, the paternal great-grandparents. The father, who lived in the home, was found responsible for neglect due to his failure to protect the children from abuse and the unsanitary conditions of his living space. Following removal, the court established objectives for the father to correct the neglect, including maintaining sobriety, obtaining appropriate housing, and prioritizing the children's needs. DCYF provided referrals and assistance to help the father meet these objectives.After several review hearings, the father showed substantial compliance, particularly in bonding with the children and engaging in treatment and counseling, but he failed to secure adequate housing. At a permanency hearing, he was granted a 90-day extension to resolve housing issues and cooperate with an Interstate Compact home study for placement in Vermont. During the extension, the father regressed—he canceled visits, relapsed into substance use, delayed paperwork, and faced criminal charges, leading DCYF to shift from supporting reunification to seeking termination of parental rights. The trial court found that despite DCYF’s reasonable efforts, the father failed to correct the neglect conditions and that termination was in the children's best interests.The Supreme Court of New Hampshire reviewed the case and affirmed the trial court’s decision. The court held that the father did not correct the conditions of neglect within twelve months, plus the extension, and that DCYF made reasonable efforts to facilitate reunification. The court also determined that termination of parental rights served the children’s best interests, supported by evidence of their improved well-being in a stable foster home. The trial court’s findings were upheld as supported by the record and not erroneous as a matter of law. View "In re H.H." on Justia Law

A young child was removed from her parents’ custody shortly after birth due to concerns about substance exposure and was placed in foster care. Her mother’s parental rights were terminated, and her father was incarcerated for much of her early life. After the mother’s rights were terminated, the child lived with foster parents for several years. When the father later sought to revoke the child’s commitment, the state agency sought to remove the child from the foster home and place her with a paternal relative, prompting the foster parents to intervene in the case to contest the proposed change.The Superior Court, Juvenile Matters, initially permitted the foster parents limited intervention, but then granted the agency’s motion to remove them as intervenors, relying on an appellate decision that limited foster parent participation. The foster parents appealed, and the Connecticut Supreme Court reversed the trial court’s order removing them as intervenors, restoring their status and remanding the case for further proceedings. On remand, without objection from counsel, the trial court appointed the state agency as the child’s statutory parent. The foster parents’ attorney later moved to open (i.e., revisit) this appointment, claiming she had misunderstood the legal implications and failed to object due to that mistake. Before a hearing on this motion could be held, the trial court granted an adoption petition in favor of the child’s paternal relatives. After the adoption, the trial court denied the foster parents’ motion to open as moot, finding it could offer no practical relief.The Connecticut Supreme Court held that the trial court erred by failing to consider the merits of the foster parents’ timely motion to open before proceeding with the adoption. The Supreme Court reversed the denial of the motion to open and remanded the case, instructing the trial court to hold a hearing and decide the motion, including an analysis of the child’s best interests. View "In re Jewelyette M." on Justia Law