Justia Juvenile Law Opinion Summaries

A young woman, an enrolled member of the Choctaw Nation, was raised in a dysfunctional and abusive environment on the Choctaw Nation Reservation. At seventeen-and-a-half years old, she orchestrated a plan for her fifteen-year-old boyfriend and eighteen-year-old friend to murder her parents, purportedly motivated by a fabricated pregnancy and the belief that eliminating her parents was necessary for her future with her boyfriend. The friends carried out the murders as planned, and all three attempted to flee in her parents' car, but were apprehended after crashing nearby.The United States charged her in the Eastern District of Oklahoma with two counts of murder in Indian country, conspiracy to commit murder in Indian country, and carjacking resulting in death. The government successfully moved to transfer her case from juvenile court to adult federal court. She appealed the transfer, but the United States Court of Appeals for the Tenth Circuit affirmed. Ultimately, she pleaded guilty to the conspiracy charge, and the District Court accepted her plea and dismissed the remaining charges. At sentencing, the District Court applied a two-level vulnerable-victim enhancement due to her father’s health conditions and calculated a Guidelines range of life imprisonment. After considering mitigating factors, including her juvenile status and personal history, the District Court imposed a below-guideline sentence of 456 months. Her coconspirators received shorter sentences.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the District Court had subject-matter jurisdiction and whether the sentence was reasonable. The Court held that conspiracy to commit murder in Indian country is a generally applicable federal crime, not limited by the Major Crimes Act’s enumeration, and thus falls within the District Court’s jurisdiction under 18 U.S.C. § 3231. The Court also concluded that the sentence was neither procedurally nor substantively unreasonable. The conviction and sentence were affirmed. View "United States v. Martin" on Justia Law

A high school student, JR, reported to law enforcement that her stepfather, Charles Merrell, had engaged in a pattern of inappropriate sexual conduct over several years. JR described repeated incidents, including touching, massaging, and pinching her bare buttocks, forced intimate dancing and hugging in which she felt his genitals against her, and other behaviors such as rubbing her bare stomach and kissing her neck. She also recounted that Merrell initiated conversations about masturbation, encouraged her to “explore” her body, and tried to justify his actions as helping her. Merrell admitted most of the physical contact but claimed his motives were innocent.Following a police investigation, Merrell was charged in the District Court of Lincoln County, Wyoming, with two counts of third-degree sexual abuse of a minor under Wyoming Statute § 6-2-316(a)(iv). The prosecution amended the charges for clarity after Merrell requested a bill of particulars. At trial, JR testified in detail about the conduct. The jury found Merrell guilty on both counts. The district court denied Merrell’s motions for acquittal and for a new trial, sentencing him to concurrent prison terms.On appeal to the Supreme Court of the State of Wyoming, Merrell challenged the statute as unconstitutionally vague, the sufficiency of the evidence, the unanimity of the jury verdict, the admission of expert testimony on “grooming,” alleged prosecutorial misconduct, and cumulative error. The Supreme Court held that the statute was neither vague on its face nor as applied; that sufficient evidence supported the convictions; that no unanimity violation or instructional error occurred; that the expert testimony and prosecution’s arguments were properly admitted or not prejudicial; and that cumulative error analysis was unwarranted. The Court affirmed the convictions and sentences. View "Merrell v. State" on Justia Law

A twelve-year-old juvenile was accused of aggravated sexual assault based on allegations that he assaulted and strangled a peer in the woods, causing her to lose consciousness and suffer severe pain. The victim reported the incident to her mother, and a forensic interview provided further details. Physical evidence, including “blood-like” stains and seminal fluids, was observed on clothing worn by the victim during the alleged incident. The State filed a delinquency petition and sought a nontestimonial identification order (NTO) under Vermont Rule of Criminal Procedure 41.1 to obtain DNA evidence from the juvenile.The Superior Court, Washington Unit, Family Division, granted the State’s request for the NTO. The juvenile moved to quash the order, arguing that Rule 41.1 did not permit NTOs in delinquency proceedings because adjudication as a delinquent child is not a criminal conviction and does not result in imprisonment. The family division denied the motion, reasoning that Rule 41.1’s definition of “offense” refers to the nature of the crime itself, not the possible consequences for the juvenile, and noted that the rule specifically applies to persons subject to delinquency proceedings. The court also observed that cases could be transferred to criminal court, making imprisonment a possibility.The Vermont Supreme Court reviewed the case on interlocutory appeal and applied a de novo standard of review to the interpretation of procedural rules. The Court held that Rule 41.1, by its plain language, applies to juveniles in delinquency proceedings and does not require that the person named in the NTO be subject to imprisonment for more than one year. The Court affirmed the family division’s denial of the motion to quash, concluding that the State’s request satisfied Rule 41.1 and that issuing NTOs in delinquency cases is consistent with statutory and rehabilitative purposes. View "In re C.L." on Justia Law

A sixteen-year-old, K.B., was the subject of a juvenile delinquency proceeding for possession of a controlled substance. During the hearing, K.B. alleged that she was subjected to physical and emotional abuse by her mother and grandmother. The circuit court judge, upon hearing these allegations, initiated a separate administrative proceeding and ordered the West Virginia Department of Human Services (DHS) to investigate and report on the allegations, particularly because five other children resided in the home. Despite DHS finding the allegations unsubstantiated after multiple investigations and interviews, the court continued to direct further investigation and ultimately ordered DHS to “open a case” for services following a separate disclosure of alleged sexual abuse by one sibling against another. The administrative proceeding was repeatedly reopened and extended, with the circuit court directing specific actions, such as ordering a psychosexual evaluation of the alleged perpetrator, even when law enforcement had not filed any charges.Over several months, status hearings were held jointly with the ongoing juvenile delinquency case. The circuit court’s involvement extended to specifying interventions and requiring further DHS actions, despite the lack of substantiated abuse findings and objections from DHS and the prosecutor about the court’s authority. Eventually, the circuit court entered an order directing DHS to file a formal child abuse and neglect petition within fourteen days or face contempt, prompting DHS to seek relief from the Supreme Court of Appeals of West Virginia.The Supreme Court of Appeals of West Virginia granted a writ of prohibition, holding that the circuit court exceeded its legitimate judicial authority and violated the separation of powers by ordering DHS to file an abuse and neglect petition. The court found that statutory authority to investigate and initiate such petitions resides solely with the executive branch, and the judiciary cannot compel the executive to file a petition in the absence of statutory prerequisites. The June 4, 2026, order was found clearly erroneous and unenforceable. View "State ex rel. Department of Human Services v. Cohee" on Justia Law

The case involves two parents whose children were removed from their home after allegations of truancy, poor living conditions, physical abuse, and felony child abuse charges. After an unsuccessful improvement period, the parents stipulated to certain allegations and were adjudicated as abusive and neglectful. The circuit court initially granted them post-adjudicatory improvement periods, but they failed to comply with requirements, tested positive for cocaine, and missed a status hearing. Their improvement periods were terminated, and at the dispositional hearing, although there were motions to terminate parental rights, the court decided it was not in the children's best interests to do so. Instead, the children were placed in the temporary custody of the Department of Human Services (DHS), with limited visitation granted to the parents.Subsequently, the parents and their counsel did not participate in several permanency review hearings due to confusion about their roles and responsibilities after the initial disposition. Notices were inconsistently sent, and the parents were functionally excluded from key proceedings, including multi-disciplinary team meetings and decisions about visitation, which was eventually discontinued. The guardian ad litem later moved to modify disposition and terminate parental rights. The circuit court "reappointed" counsel and held a contested hearing where the parents argued they had not received proper notice. The court found a material change in circumstances and terminated parental rights, reasoning that the children no longer wished to be reunified and had bonded with their foster family.The Supreme Court of Appeals of West Virginia reviewed the case. It held that the circuit court substantially disregarded statutory and procedural requirements by functionally excluding the parents and failing to make the statutory findings necessary for termination of parental rights under West Virginia Code § 49-4-604(c)(6). The court vacated the order terminating parental rights and remanded for further proceedings consistent with statutory and procedural requirements. View "In re A.S." on Justia Law

A juvenile, A.E.R., was charged in a delinquency petition with violations related to drug distribution and money laundering, alleged to have occurred when she was seventeen years old. The charges included class 2 and class 3 felonies under the Colorado Organized Crime Control Act and other statutes. The same alleged criminal enterprise led to charges against five adults and two other juveniles. Upon being charged, A.E.R., through her attorney, promptly requested a preliminary hearing, and the district court scheduled the hearing.Before A.E.R.'s hearing took place, the People secured grand jury indictments against her adult co-defendants for related conduct. The district court, after briefing, accepted the People’s argument that the grand jury’s finding of probable cause in the adults’ case was sufficient to establish probable cause for A.E.R., thereby denying her request for a preliminary hearing. The district court reasoned that the statutory right to a preliminary hearing was extinguished by the grand jury’s determination in the separate case.The Supreme Court of Colorado reviewed the matter under its original jurisdiction, finding that the issue was significant and not previously addressed. The court held that the plain language of section 19-2.5-609(1) of the Children’s Code entitles a juvenile charged with a class 1, 2, or 3 felony to a preliminary hearing upon proper request, regardless of grand jury proceedings against others. The grand jury indictment against adult co-defendants did not affect A.E.R.’s statutory right. The court made its order to show cause absolute, ruling that the district court erred in denying the preliminary hearing, and remanded the case for further proceedings consistent with its opinion. View "In the Interest of Juvenile: A.E.R." on Justia Law

A fifteen-year-old defendant with an intellectual disability was arrested and charged with first-degree murder and tampering with evidence after the death of a younger child. Unable to post a high cash bond, the defendant remained incarcerated pretrial. At arraignment, defense counsel raised concerns about the defendant’s competency to stand trial. Over the next three years and three months, the case was repeatedly delayed due to defense counsel’s failure to schedule and facilitate a competency evaluation. The defendant was ultimately found competent to stand trial after several years in custody. Additional delays occurred, including a fourteen-month period during which the State pursued an interlocutory appeal. The first trial ended in a mistrial, while the second resulted in convictions for second-degree murder and tampering with evidence, leading to an adult prison sentence.After conviction, the defendant argued that his constitutional right to a speedy trial had been violated. The District Court for Santa Fe County rejected this claim, attributing much of the delay to defense counsel. The New Mexico Court of Appeals affirmed, holding that the delays caused by defense counsel’s neglect should be attributed to the defendant and that the State’s conduct did not warrant relief.The Supreme Court of the State of New Mexico reversed. Applying the Barker v. Wingo factors, the court held that the nearly six-year delay was extraordinary and presumptively prejudicial. It concluded that because the delays were caused by defense counsel’s neglect, and the defendant’s intellectual disability prevented him from meaningfully participating or acquiescing, the delays could not be weighed against the defendant. The State also failed to monitor and move the case forward. The court held that the defendant’s speedy trial rights were violated, vacated the convictions, and ordered dismissal of the indictment. View "State v. Villalobos" on Justia Law

A 16-year-old defendant was questioned by Georgia Bureau of Investigation (GBI) agents following the death of his infant daughter in March 2020. The interviews occurred at a Florida hospital on March 5 and 6, and at the Clinch County Sheriff’s Office in Georgia on March 11. During these interviews, the defendant made statements about the events leading to the child’s injuries, including an admission of hitting her during the March 11 interview. At the time of the interviews, he was not living with his parents and no parent or guardian was present during questioning. The March 11 interview included Miranda warnings, which the defendant verbally acknowledged and waived in writing.The Superior Court of Clinch County held a hearing on the defendant’s omnibus motion to suppress his statements. After hearing testimony and reviewing audio and video evidence, the trial court granted the motion to suppress all three statements. The court found that the defendant was in custody during each interview and that Miranda warnings should have been provided for the March 5 and 6 interviews. For the March 11 interview, the trial court concluded that the defendant did not voluntarily, knowingly, or intelligently waive his Miranda rights based on his age, education, lack of guardian presence, and the brief explanation of his rights.The Supreme Court of Georgia reviewed the trial court’s decision. It held that the trial court’s findings regarding custody for the March 5 and 6 statements were insufficient for appellate review and remanded for further factual findings. However, the Court determined that the defendant voluntarily, knowingly, and intelligently waived his Miranda rights during the March 11 interview under the totality of the circumstances. The Court reversed the suppression of the March 11 statement, vacated the suppression of the March 5 and 6 statements, and remanded the case for further proceedings. View "THE STATE v. MCGRIFF" on Justia Law

The case concerns a juvenile, X.G., who was implicated in a robbery involving four individuals, three of whom were armed. The victim was accosted as he was removing his children from his car, robbed of a watch, necklace, and wallet containing cash. X.G. was identified as one of the participants and was charged with multiple offenses, including robbery, child endangerment, handgun possession, and grand theft. Ultimately, X.G. pled no contest to grand theft, with the other charges dismissed.Following the plea, the Superior Court of San Francisco County terminated X.G.’s probation as unsuccessful and held a disposition and restitution hearing. At this hearing, X.G. argued that, in light of a recent amendment to Welfare and Institutions Code section 730.6, liability for restitution should be apportioned based on each participant’s responsibility, especially since adults named in the arrest warrant were also involved. The prosecutor contended that, as X.G. was the only adjudicated offender, the court was required to impose full restitution. The juvenile court agreed with the prosecution and ordered X.G. to pay the full restitution amount to the victim, reasoning that apportionment was not possible because there were no other co-offenders before the court.The California Court of Appeal, First Appellate District, Division Three, reviewed the restitution order. The court held that, while section 730.6 now requires apportionment of restitution among adjudicated juvenile co-offenders, it also gives the juvenile court discretion to consider whether “compelling and extraordinary reasons” exist to award less than full restitution. Such reasons can include the involvement of other participants who have not been adjudicated in the same proceeding. The appellate court found that the juvenile court misunderstood its discretion and failed to consider whether the circumstances warranted less than full restitution. The restitution order was reversed and remanded for reconsideration in light of the proper standard. View "In re X.G." on Justia Law

A juvenile, C.M., was subject to delinquency and probation violation proceedings in Tehama County and Glenn County, respectively, after engaging in criminal conduct and violating probation. Both cases were initiated while C.M. was still 17 years old. During the proceedings, evidence emerged that C.M.’s parents resided in Mariposa County. By the time the courts considered transferring the cases, C.M. had turned 18. Both the Tehama County Superior Court and the Glenn County Superior Court found that C.M.’s legal residence was with his parents in Mariposa County and ordered the transfer of the respective cases to Mariposa County Superior Court for disposition.The Mariposa County Superior Court accepted the transfers, but Mariposa County appealed both orders. On appeal, Mariposa County argued that the transferring courts erred in determining Mariposa County as C.M.’s county of residence because C.M. was no longer a minor at the time of the transfer orders. Mariposa County also contended that the transferring courts failed to consider whether the transfer would be in C.M.’s best interest as required by California Rules of Court, rule 5.610(e).The California Court of Appeal, Third Appellate District, reviewed the statutory framework of Welfare and Institutions Code section 750 and relevant rules. The court concluded that, because C.M. was no longer a minor at the time of the transfer-out hearings, his residence could not be derived from that of his parents for the purposes of section 750. The court further held that, under the first clause of section 750, there was no basis for transferring the cases to Mariposa County because C.M. did not reside there at the relevant time. Accordingly, the Court of Appeal reversed both transfer-out orders. View "In re C.M." on Justia Law