Justia Juvenile Law Opinion Summaries

A young child was removed from her mother’s care, along with her two siblings, due to concerns of neglect and abuse. After initial placement with their maternal grandmother, the grandmother asked for the children to be removed, and the subject child was subsequently placed with a licensed foster parent, J.D., where she remained. The child’s brother was later hospitalized and, upon discharge, was placed with the grandmother, while the subject child remained with J.D. Over the course of the proceedings, professional testimony described the child’s attachment disorder, trauma history, and the risks posed by placement changes. Reports also indicated the child was thriving in her current placement and that sibling reunification was not in her best interest due to safety and emotional concerns.The Fourth Judicial District Court, Missoula County, held multiple hearings regarding placement and permanency. After terminating parental rights and granting permanent legal custody to the Montana Department of Public Health and Human Services, the court denied the grandmother’s request for placement, finding good cause to depart from statutory placement preferences based on the child’s extraordinary mental and emotional needs. The court incorporated findings from previous orders, relied on professional testimony and a report from the Court Appointed Special Advocate, and approved adoption by J.D. as the permanency plan.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in approving adoption as the permanency plan and denying the grandmother’s placement request. The Supreme Court held that, despite some imprecise language, the District Court applied the correct statutory standards, made sufficient findings regarding the child’s best interests, and did not abuse its discretion. The Supreme Court affirmed the District Court’s order. View "In re M.L.O.-L." on Justia Law

The case concerns a father and mother with four minor children. Dependency jurisdiction was initially asserted over the children due to the father’s alcohol abuse and the mother’s failure to protect the children. After the parents entered into a stipulation, restrictions on the father’s visitation were removed, and joint custody was restored. However, a subsequent domestic violence incident involving the father led to a new dependency petition. The father was accused of slapping the mother while possibly intoxicated, which was witnessed by the eldest child. The investigation also revealed prior domestic violence calls. As a result, the children were detained from the father and released to the mother, with the father granted monitored visitation.The Superior Court of Los Angeles County sustained allegations against the father for domestic violence and alcohol abuse, declared the children dependents, and removed them from the father’s custody. The mother was given family preservation services, while the father received enhancement services and monitored visitation. At a six-month review hearing, it was reported that the father completed a substance abuse program but continued to engage in concerning behavior, including leaving threatening voicemails, appearing intoxicated, and being physically aggressive toward the mother. The mother obtained a restraining order, and the Department of Children and Family Services recommended terminating jurisdiction with sole custody to the mother and monitored visitation for the father.The California Court of Appeal, Second Appellate District, Division Eight, reviewed whether the lower court erred in requiring the father to pay for a professional visitation monitor as a condition of visitation without considering his ability to pay or reasonable alternatives. The appellate court held that the juvenile court abused its discretion by not inquiring into the father’s financial ability or considering alternatives such as an unpaid monitor. The order requiring the father to pay for a professional monitor was reversed and remanded for further proceedings; the custody order was otherwise affirmed. View "In re Reyna R." on Justia Law

A 16-year-old juvenile was charged with serious offenses, including first degree sexual assault, terroristic threats, assault by strangulation or suffocation, and third degree domestic assault, all stemming from two incidents involving his then-girlfriend. After an investigation initiated by a friend's report, law enforcement gathered police reports, photographs, text message screenshots, and a video interview of the alleged victim. The State moved to transfer the juvenile’s case from the juvenile court to the adult docket of the county court.At the transfer hearing in the County Court for Buffalo County, the State did not call any witnesses and instead offered documentary and video exhibits without authentication or supporting testimony. The juvenile’s counsel objected on due process, foundation, and confrontation grounds, arguing he could not cross-examine or otherwise challenge the evidence. The court overruled the objections, received the evidence, and concluded that most statutory factors favored transfer, despite finding some factors supported retention in juvenile court. The court found the State met its burden by a preponderance of the evidence and ordered the case transferred.The Nebraska Court of Appeals, in a split decision, affirmed the juvenile court’s actions. The majority held that the juvenile’s due process rights were satisfied because he had a hearing, representation by counsel, and a specific written decision, relying on the standards set forth in Kent v. United States. The dissent disagreed, arguing the lack of authentication and sponsoring witnesses for the State’s exhibits deprived the juvenile of due process.The Nebraska Supreme Court reviewed the case and affirmed the Court of Appeals’ decision. The Supreme Court held that the juvenile’s due process rights were not violated under these facts, as counsel had access to the State’s evidence and an opportunity to respond, and the evidence bore sufficient indicia of reliability. The Court also concluded that the juvenile court did not abuse its discretion in ordering the transfer to adult court. View "In re Interest of Aaden S." on Justia Law

A juvenile was arrested at age twelve for the murder and aggravated robbery of a convenience store clerk. Surveillance video showed the juvenile entering the store multiple times, stealing items, and ultimately shooting the victim eight times. After the murder, he calmly stole additional items and discarded evidence. The juvenile confessed to the crimes and exhibited a history of violent and antisocial behavior, documented by family members, school officials, therapists, and juvenile detention staff. Multiple psychological evaluations were conducted, yielding conflicting diagnoses of autism, conduct disorder, and schizophrenia, but all agreed he knew right from wrong.The juvenile division of the Miller County Circuit Court designated him as an extended juvenile jurisdiction (EJJ) offender. He was adjudicated delinquent by a jury, committed to the Arkansas Division of Youth Services (DYS), and the imposition of an adult sentence was suspended pending further review. The Arkansas Court of Appeals affirmed these rulings. Over several years, DYS provided rehabilitative services. After several petitions concerning release and adult sentencing, the State filed a petition to impose an adult sentence as the juvenile approached age twenty, citing ongoing concerns about rehabilitation and public safety. At the subsequent hearing, DYS staff testified that the juvenile had made progress and completed treatment goals, but the State introduced evidence of recent violent incidents and inconsistencies in staff testimony.The Supreme Court of Arkansas reviewed the circuit court’s order imposing an adult sentence, applying a clearly erroneous standard. The court affirmed the circuit court’s findings that the juvenile was not amenable to treatment and that public safety required the imposition of an adult sentence. The court held that the circuit court’s assessment of the statutory factors and credibility determinations were not clearly erroneous, and affirmed the life sentence with the possibility of parole after thirty years. View "MERRELL v. STATE OF ARKANSAS" on Justia Law

Four juveniles conspired to rob a victim of vaping products in Colorado in 2019. During the incident, one of the juveniles, who is Black, shot and killed the victim. All four were initially charged with felony murder, aggravated robbery, and conspiracy to commit aggravated robbery. Subsequent investigation revealed that the shooter acted alone in confronting and shooting the victim, while the other three, including two non-Black juveniles, had more limited roles and cooperated with law enforcement. The two non-Black juveniles received plea deals allowing them to be tried in juvenile court and were sentenced to two years in the Division of Youth Services, while the two Black defendants, including the shooter, were prosecuted in district court and faced substantially harsher potential sentences.The District Court for Arapahoe County denied the shooter's motion to dismiss for selective prosecution, finding that he was not similarly situated to his non-Black codefendants due to his greater culpability as the shooter. The court also found that statistical evidence provided did not establish discriminatory purpose by the prosecution. The case proceeded to trial, and a jury convicted the shooter, who was sentenced to life in prison with the possibility of parole after forty years. On appeal, the Colorado Court of Appeals affirmed the trial court’s denial of the motion to dismiss, agreeing that the shooter was not similarly situated to the other defendants. The appellate division did not address whether the statistical evidence sufficed to show discriminatory purpose.The Supreme Court of Colorado affirmed the judgment of the Court of Appeals. It held that the defendant failed to establish a claim of selective prosecution because he did not show a discriminatory effect or purpose. Specifically, he was not similarly situated to his non-Black codefendants, and his statistical evidence did not demonstrate that similarly situated non-Black individuals were treated differently. View "Mitchell v. People" on Justia Law

A teenager, S.G.H., was accused of using generative artificial intelligence to create explicit composite images of three underage female classmates by digitally blending their actual faces and clothed bodies with computer-generated images of naked intimate body parts. These manipulated images were discovered on S.G.H.’s school email account during a police investigation prompted by an automated alert regarding inappropriate content. The images made it appear as though the classmates were nude, but the explicit portions were entirely computer-generated and not derived from actual photographs of the victims.In the Morgan County District Court, the People of the State of Colorado filed a delinquency petition charging S.G.H. with six counts of sexual exploitation of a child under section 18-6-403(3)(b) and (3)(b.5), C.R.S. (2024). S.G.H. moved to dismiss, arguing that the images did not constitute “sexually exploitative material” under the law then in effect, since they did not depict actual naked children and the explicit body parts were computer-generated. The District Court denied the motion, interpreting the statute as encompassing digitally manipulated images bearing a child’s actual features combined with simulated intimate parts, and found probable cause for all charges.The Supreme Court of Colorado reviewed the case under its original jurisdiction. The Court held that, as of December 2023, the statutory definition of “sexually exploitative material” did not cover images created or altered using generative AI to fabricate explicit content. The Court found that recent legislative amendments expanding the definition to include such computer-generated images represented a change, not a clarification, of the law. Concluding that the District Court erred in finding probable cause, the Supreme Court made absolute its order to show cause and remanded with instructions to dismiss all charges against S.G.H. View "People ex rel. S.G.H." on Justia Law

Three advocacy organizations filed suit against the South Carolina Department of Juvenile Justice and its executive director, seeking institutional reforms to address alleged unconstitutional and unlawful conditions in the state’s juvenile detention facilities. The plaintiffs alleged that the facilities were overcrowded, understaffed, and dangerous, resulting in violence, isolation, and inadequate services for juveniles. They based their standing on their advocacy and direct representation work with affected youth, and described both the harm to juveniles and the impact on their own organizational missions.The United States District Court for the District of South Carolina dismissed the complaint without prejudice. The district court found that Disability Rights South Carolina (DRSC) had standing to sue on behalf of certain juveniles, but those claims were rendered moot when those juveniles left custody. The court also determined that Justice 360 had standing in its own right but concluded that its claims failed on the merits. The South Carolina State Conference of the NAACP was found to lack standing. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Fourth Circuit held that the advocacy organizations lacked Article III standing to pursue the claims because they failed to demonstrate a sufficient personal stake in the outcome. The court found that DRSC did not meet the requirements for associational standing as its constituents lacked indicia of membership. The court also concluded that none of the organizations suffered a cognizable injury directly caused by the defendants’ actions, but rather incurred self-imposed costs through voluntary advocacy. The court further held that the plaintiffs could not bring claims under 42 U.S.C. § 1983 for the violation of rights belonging to others, as they had not alleged violations of their own federal rights. The dismissal was affirmed. View "South Carolina State Conference of the NAACP v. South Carolina Department of Juvenile Justice" on Justia Law

A juvenile, S.M., was alleged to have committed theft and shoplifting. Initially released pending resolution, S.M. repeatedly absconded, leading to her detention to secure her attendance and protect others’ property. After being detained at the Youth Services Center, S.M. was moved to the Youth Shelter House, but following further incidents of insubordination and unauthorized departures, the trial court ordered her returned to the Youth Services Center.The Superior Court of the District of Columbia issued the order changing S.M.’s place of detention from the Youth Shelter House back to the Youth Services Center. S.M. appealed, arguing that such a move to a more restrictive facility required a specific finding that it was necessary for safety or to secure her appearance, as per D.C. Code § 16-2310(a). The District countered that the order was not subject to the emergency interlocutory review provision of D.C. Code § 16-2328 and that the trial court did not need to make such a finding for placement decisions.The District of Columbia Court of Appeals reviewed the case and concluded that (1) it had jurisdiction under Section 16-2328 to review the order, as it was a detention order; (2) a child can challenge both the fact of detention and the specific place of detention on an emergency interlocutory appeal; and (3) the trial court, when deciding the specific place of detention, is not required to find that placement in a particular facility is necessary to protect safety or ensure appearance. Instead, the selection of the place of detention is a discretionary decision guided by statutory goals, including placing children in the least restrictive setting necessary. The court clarified that the statutory detention criteria apply to the decision to detain, not to the specific location of detention. The disposition affirmed the trial court’s order. View "In re S.M." on Justia Law

A seventeen-year-old was charged in the St. Francis County Circuit Court with three counts of capital murder and one count of felony theft after his mother, her boyfriend, and his twelve-year-old sister were found shot to death in their home. The evidence included the recovery of the victims’ vehicle, a firearm, gunshot residue on the accused’s clothing, and DNA evidence. The accused denied involvement but was contradicted by testimony from his four-year-old sister and other evidence. The defense presented testimony about his background, mental health, and the potential for rehabilitation.After the accused moved to transfer the case to the juvenile division, the St. Francis County Circuit Court held a hearing and denied the motion. On interlocutory appeal, the Arkansas Court of Appeals found that the circuit court had failed to address a required statutory factor and remanded for additional findings. The circuit court entered an amended order again denying transfer. The accused then appealed to the Arkansas Supreme Court.The Arkansas Supreme Court first ruled that the accused's constitutional challenge to Arkansas Code Annotated section 9-27-318 was not preserved for appellate review because it was not raised in the circuit court. The court also held that the circuit court properly exercised subject-matter jurisdiction. Reviewing the denial of transfer for clear error, the Arkansas Supreme Court concluded that the amended order adequately addressed all statutorily required factors, gave appropriate weight to the seriousness and violent nature of the offenses, and was not clearly erroneous. The Supreme Court affirmed the circuit court’s denial of the motion to transfer the case to the juvenile division. View "ROLFE v. STATE OF ARKANSAS" on Justia Law

The case concerns two children whose parents were subject to dependency proceedings after allegations of domestic violence and failure to protect were brought by a county child welfare agency. The children were ultimately removed from their parents' custody and placed with extended family members. Over the course of the proceedings, the social services department conducted multiple inquiries with both parents and a number of extended family members about possible Native American heritage, as required under the Indian Child Welfare Act (ICWA) and related California law. Each person asked denied any such heritage.After the initial dependency petition, the Superior Court of Los Angeles County sustained the allegations, ordered reunification services, and later returned the children to their parents. Following further incidents of domestic violence, the children were again removed, and supplemental petitions were sustained. The agency continued its ICWA inquiry, interviewing additional family members but did not specifically question the paternal grandfather, though he was interviewed on other subjects. The Superior Court terminated parental rights after finding the children adoptable and determined there was no reason to know the children were Indian children under ICWA.The California Court of Appeal, Second Appellate District, Division Five, reviewed whether the agency’s failure to inquire specifically of the paternal grandfather required reversal of the order terminating parental rights. The court held that, under the standard articulated in In re Dezi C. (2024) 16 Cal.5th 1112, a finding that the initial ICWA inquiry was adequate is supported by substantial evidence where the agency interviewed the parents and several extended family members, even if not every possible relative was asked. The court found the agency’s efforts sufficient and affirmed the order terminating parental rights. View "In re Bella L." on Justia Law