Justia Juvenile Law Opinion Summaries

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama. The district court denied his motion in 2016, and Mullins’s appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" on Justia Law

A fifteen-year-old, J.Q.R., sold fentanyl-laced pills to two classmates, B.H. and R.J., resulting in R.J.'s death from an overdose. During the investigation, police discovered evidence implicating J.Q.R.'s father in illegal drug activities. The father waived J.Q.R.'s Miranda rights twice, leading to J.Q.R. making incriminating statements to the police.The Hendricks Superior Court admitted J.Q.R.'s statements into evidence over his objections, arguing that his father had an adverse interest due to his own criminal conduct. The court adjudicated J.Q.R. as a delinquent child. The Indiana Court of Appeals affirmed the trial court's decision.The Indiana Supreme Court reviewed the case and held that an adverse interest may arise if an adult stands to personally benefit from waiving a child's rights to the child's detriment. The court found that the State failed to prove beyond a reasonable doubt that the father had no adverse interest when he waived J.Q.R.'s rights, given the evidence of the father's own drug activities. Therefore, the trial court erred in admitting J.Q.R.'s statements.However, the Indiana Supreme Court concluded that the error was harmless because independent evidence, such as text messages, established that J.Q.R. knew the pills contained fentanyl. Consequently, the court affirmed the trial court's adjudication of J.Q.R. as a delinquent child. View "J.Q.R. v. State" on Justia Law

In this case, the Los Angeles County Department of Children and Family Services (DCFS) became involved with a family after law enforcement discovered child pornography in the parents' home. Both parents admitted to possessing child pornography, and the mother admitted to posting inappropriate images of their daughter, M.V., online. M.V. was subsequently placed with her paternal grandparents, and the juvenile court sustained allegations of sexual exploitation against both parents, declaring M.V. a dependent child and removing her from her parents' custody. The parents received reunification services until November 2020, and in December 2021, the juvenile court terminated their parental rights. However, this order was vacated on appeal, and the case was remanded for a supplemental bonding study and a new permanency planning hearing.On remand, a new expert conducted a bonding study, and the permanency planning hearing took place in June 2024. The court reviewed extensive documentary evidence, including reports on M.V.'s well-being, her relationship with her parents and grandparents, and her expressed wishes to be adopted by her grandparents. The expert, Dr. Gonzalez, concluded that M.V. had a secure attachment to both parents and that terminating the parental relationship could be detrimental to her. However, the court found that the parents had not proven the beneficial parental relationship exception, noting that the expert's opinions were based more on general psychological principles than on the specific facts of the case.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case and affirmed the juvenile court's order terminating parental rights. The appellate court found that the juvenile court did not abuse its discretion in rejecting the expert's opinions and that the evidence did not compel a finding in favor of the parents. The court also addressed and dismissed allegations of judicial bias and due process violations raised by the parents. View "In re M.V." on Justia Law

D.F. (father) appealed the juvenile court's orders appointing a guardian for his son, J.F., and terminating jurisdiction under Welfare and Institutions Code section 366.26. He argued that the court and the Los Angeles County Department of Children and Family Services (the Department) failed to meet their initial inquiry duties under the Indian Child Welfare Act (ICWA) and related California statutes (Cal-ICWA).The juvenile court had appointed a guardian for J.F. and terminated its jurisdiction. Father sought a conditional reversal of the guardianship order and a remand to ensure compliance with ICWA and Cal-ICWA. No respondent's brief was filed, but father, the child's counsel, and the Department filed a joint stipulation for conditional affirmance of the guardianship, limited reversal of the termination of jurisdiction, and remand for further inquiry.The California Court of Appeal, Second Appellate District, Division Five, reviewed the case. The court found that the Department failed to contact maternal relatives to inquire about the child's potential Indian ancestry, constituting reversible error. However, the court disagreed with the need to contact the paternal great-aunt, as she is not considered an "extended family member" under ICWA.The court conditionally affirmed the guardianship order but conditionally reversed the order terminating dependency jurisdiction. The case was remanded to the juvenile court with instructions to order the Department to interview the maternal grandmother and aunt about the child's Indian ancestry and report the findings. If no further inquiry or notice to tribes is necessary, the termination order will be reinstated. If additional inquiry or notice is required, the court must ensure compliance with ICWA and Cal-ICWA. View "In re J.F." on Justia Law

J.B. (Minor) was placed with A.R. (De Facto Parent) for nearly two years after being removed from B.B. (Mother) and J.S. (Father). Parents filed petitions under Welfare and Institutions Code section 388 seeking additional reunification services and increased visitation. The trial court granted these petitions but did not remove Minor from De Facto Parent's care. De Facto Parent appealed, arguing that the juvenile court should not have granted additional reunification services as Parents failed to show changed circumstances and that it was not in Minor’s best interest.The Superior Court of Riverside County granted the section 388 petitions, providing Parents with six months of reunification services and increased visitation. The court noted that Minor would remain with De Facto Parent for the time being, with the goal of eventually returning Minor to Parents. The section 366.26 hearing, which would address the termination of parental rights and adoption, was vacated.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court agreed with the Riverside County Department of Public Social Services that De Facto Parent did not have standing to appeal the grant of the section 388 petitions. The court noted that as a de facto parent, A.R. did not have the right to reunification services, visitation, custody, or placement of Minor. The appeal was dismissed for lack of standing. View "In re J.B." on Justia Law

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

M.T., a 16-year-old juvenile, was charged with simple assault and willful concealment. His parents expressed that they did not feel safe with him at home and requested residential treatment. M.T. was placed in shelter care but was removed due to dangerous behavior, including physical altercations and property damage. The shelter exercised its right to terminate treatment, leading to M.T.'s placement at the Sununu Youth Services Center (SYSC).The Circuit Court held an adjudicatory hearing where M.T. pled true to the charges. The court scheduled a dispositional hearing and, in the interim, heard arguments regarding M.T.'s placement. The juvenile probation and parole officer (JPPO) testified that no alternative placements were available. The court ordered M.T. to be detained at SYSC, citing the lack of less restrictive options and the need for M.T.'s safety and supervision.At the dispositional hearing, the State recommended that M.T. remain at SYSC due to his behavior and the lack of alternative placements. M.T. requested to return to his parents, but the court found this unsuitable. The court committed M.T. to SYSC for the remainder of his minority, emphasizing the need for intensive care and supervision and the unavailability of other options. The court also ordered the Department of Health and Human Services (DHHS) to continue searching for less restrictive placements, including out-of-state options.The New Hampshire Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the trial court sustainably exercised its discretion in considering the lack of available placements and committing M.T. to SYSC. The court also found that M.T. waived his argument regarding the right to counsel during the Comprehensive Assessment for Treatment (CAT) interview. View "In re M.T." on Justia Law

T.B., a juvenile, was adjudged delinquent by the Superior Court of the District of Columbia for carrying a pistol without a license and possessing unregistered ammunition. The case arose from two Instagram live videos observed by Officer Moore of the Metropolitan Police Department. In the first video, T.B. was seen displaying a black Glock-style handgun. In the second video, T.B. was seen with a light-colored object in his waistband, which officers believed to be a firearm. When officers arrived at the scene, they found a tan-gold-colored pistol on the ground near where T.B. had been standing.The Superior Court incorporated Officer Moore’s testimony from a suppression hearing into the trial. Officer Moore testified about the events leading to T.B.'s arrest and the officers' observations from the Instagram videos. Officer Laielli also testified, describing T.B.'s behavior in the second video as characteristic of an armed gunman. The court found the evidence sufficient to prove beyond a reasonable doubt that T.B. possessed the tan-gold-colored pistol and committed him to the Department of Youth Rehabilitation Services for up to one year.On appeal, T.B. argued that the evidence was insufficient to support the court’s findings and that the trial court erred in admitting the officers’ testimony. The District of Columbia Court of Appeals reviewed the case and found that the evidence, including the Instagram videos and the officers’ observations, was sufficient to support the trial court’s findings. The appellate court also concluded that any error in admitting the officers’ testimony was harmless, as the trial court’s findings were based on its own viewing of the video evidence. The Court of Appeals affirmed the judgment of delinquency. View "In re T.B." on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law