Justia Juvenile Law Opinion Summaries

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

Two children were the subjects of a child welfare proceeding after concerns about their well-being led to the filing of a dependency petition. Their mother denied Native American heritage in earlier proceedings, but the record showed that neither the original county child welfare agency nor the juvenile court made sufficient inquiry into the children’s possible Indian ancestry, as required by both federal and California law. The case was later transferred to a different county, where the new agency also relied mainly on the mother’s denials without contacting extended maternal relatives. After the mother’s parental rights were terminated, she appealed, arguing that the agencies failed to comply with their statutory inquiry obligations.The California Court of Appeal, Second Appellate District, Division One, previously affirmed the ruling that the beneficial relationship exception did not apply but conditionally reversed the order terminating parental rights due to inadequate inquiry into possible Indian ancestry under the Indian Child Welfare Act (ICWA) and related state law. On remand, the Los Angeles County Department of Children and Family Services conducted an extensive inquiry, attempting to reach multiple maternal relatives and formally noticing several tribes and the Bureau of Indian Affairs. The responses indicated the children were not eligible for tribal membership, and most relatives did not provide information substantiating tribal affiliation.After the additional inquiry, the Superior Court of Los Angeles County found no reason to believe the children were Indian children and reinstated termination of parental rights. The mother appealed again, challenging the adequacy of the inquiry. The California Court of Appeal, Second Appellate District, Division One, held that the child welfare agency’s actions satisfied their statutory duties under ICWA and related laws. The court affirmed the juvenile court’s order terminating the mother’s parental rights, holding that the agency undertook reasonable and diligent efforts and that further inquiry or notice was not required on the facts presented. View "In re X.A." on Justia Law

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing.At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights.The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

A high school student, J.M., and her sisters initiated a physical altercation with another student at school, during which J.M. allegedly shoved a teacher into a wall and punched the student. The teacher later discovered he had a fractured rib, and the student sustained visible injuries. The school resource officer referred the incident to juvenile court, listing misdemeanor assault as the offense. A juvenile probation officer screened the case, classified it as a misdemeanor, and offered J.M. a nonjudicial adjustment agreement, which she accepted and began fulfilling by completing community service.After J.M. completed her community service but before restitution had been resolved, the State disagreed with the misdemeanor classification and filed a delinquency petition alleging three felony offenses: aggravated assault, assault, and riot, all stemming from the same incident. J.M. moved to dismiss the petition, arguing that prosecutors could not file charges after substantial compliance with the nonjudicial adjustment. The Third District Juvenile Court denied her motion, reasoning that no statute or rule precluded the State from filing a petition if it viewed the case as involving new allegations or a more serious offense.On interlocutory appeal, J.M. maintained that under Utah statutes governing nonjudicial adjustments, the probation officer’s eligibility determination should control and limit prosecutorial authority. The Supreme Court of the State of Utah reviewed the case and held that Utah’s Juvenile Code does not bar a prosecutor from filing a petition when a nonjudicial adjustment has been improperly offered for a disqualifying offense. The determination of whether an offense is disqualifying, such as a felony committed by a minor over age twelve, is an objective legal question not controlled by the referral or probation officer’s assessment. Because J.M. challenged only the prosecutor’s authority, not the felony characterization, the Supreme Court affirmed the juvenile court’s denial of the motion to dismiss. View "In re J.M." on Justia Law

A twelve-year-old child was charged with robbery and four related offenses following an incident in Baltimore City, where a victim’s purses were taken and liquid was thrown at her. Robbery, a crime of violence, anchored the juvenile court’s jurisdiction over the child under Maryland’s Juvenile Justice Reform Act, which restricts jurisdiction for children under thirteen except when charged with a violent crime or an act arising from the same incident. At the adjudicatory hearing, the magistrate found the child not involved in robbery but involved in misdemeanor theft, ruling that the timing of the force element was not established for robbery.After this finding, the child moved to dismiss the theft charge, arguing that jurisdiction was lost when the robbery count—the qualifying offense—was not sustained. The magistrate denied the motion, reasoning that jurisdiction attaches at filing and continues regardless of the adjudicatory outcome, following precedent from the Appellate Court of Maryland in In re J.B. The juvenile court proceeded to disposition, finding the child delinquent and imposing probation. The child’s exceptions and renewed motion to dismiss were also denied by a judge of the Circuit Court for Baltimore City.The Supreme Court of Maryland reviewed the case and held that jurisdiction, once attached by an allegation of a qualifying crime, continues until the child turns twenty-one unless terminated by a specific statutory mechanism. The court clarified that jurisdiction over offenses arising out of the same incident is derivative at filing but durable thereafter, unaffected by a not-sustained finding or dismissal of the anchoring violent charge. Additionally, the court rejected the child’s equal protection claim, finding a rational basis for treating children accused of violent crimes differently from those accused only of misdemeanors. The court affirmed the Circuit Court’s decision. View "In re: D.E." on Justia Law

A seventeen-year-old individual planned and carried out a violent attack resulting in the death of one person and serious injuries to two others. After purchasing a knife, he attended a dinner and sleepover with friends. Late at night, he attacked and fatally stabbed one victim, then proceeded to injure two others. The police apprehended him at the scene. He was charged with first-degree murder and two counts of attempted first-degree murder. The jury convicted him on all counts. Because he was a juvenile at the time, a separate sentencing hearing was held to consider mitigating factors under Florida law.The Circuit Court for Palm Beach County sentenced him to life without parole (LWOP) for each count, with the two attempted murder sentences running concurrently but consecutively to the murder sentence. The court announced that he would be eligible for judicial review after serving 25 years on the murder conviction, and again after serving another 25 years on the consecutive sentences for attempted murder. The defendant challenged his sentence, arguing that consecutive LWOP sentences for offenses committed in a single episode violated the Eighth Amendment, relying on Graham v. Florida. The Circuit Court denied relief, and on direct appeal, the Fourth District Court of Appeal upheld the sentences, holding that the structure provided a meaningful opportunity for release consistent with constitutional requirements. The Fourth District certified conflict with the Second District Court of Appeal’s decision in Mack v. State, which had found such consecutive sentences unconstitutional.The Supreme Court of Florida reviewed the case and held that the Eighth Amendment’s requirement of a “meaningful opportunity for release” from Graham v. Florida does not apply to juveniles convicted of homicide offenses. Instead, sentencing for juvenile homicide offenders is governed by Miller v. Alabama and Jones v. Mississippi, requiring individualized sentencing but permitting discretionary LWOP. The Court approved the Fourth District’s result, disapproved Mack, and upheld the sentences. View "Johnson v. State of Florida" on Justia Law

A mother surrendered her four-day-old twin sons at a hospital in Maryland under the Safe Haven Act, which allows parents to leave unharmed newborns at designated facilities within sixty days of birth without facing criminal or civil liability for the act of surrender. The mother left the infants with basic information but did not identify herself or provide for their ongoing care. The hospital notified the Anne Arundel County Department of Social Services, which took custody of the children and filed Child in Need of Assistance (CINA) petitions, seeking court intervention to ensure the children’s welfare. The mother was later identified and participated in the proceedings, explaining she acted out of concern for domestic violence.After de novo adjudicatory and disposition hearings in the Circuit Court for Anne Arundel County, sitting as a juvenile court, the court found that the mother’s actions constituted “neglect” under the CINA statute—specifically, that leaving the children without a legal custodian or provision for care placed them at a substantial risk of harm. The court denied the mother’s request to award custody to the father at that stage and committed the children to the Department’s custody. The mother appealed, and the Appellate Court of Maryland affirmed the juvenile court’s decision, reasoning that the absence of a legal custodian or care plan for the infants following surrender justified a finding of neglect.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court’s judgment. The Court held that a parent’s surrender of a newborn under the Safe Haven Act may constitute neglect under the CINA statute if the child is left without a legal custodian or provision for care, thus facing a substantial risk of harm. The Court also held that the Safe Haven Act’s grant of immunity from “civil liability” does not bar a CINA neglect finding, as such a finding is a non-punitive jurisdictional predicate necessary for state intervention and long-term care arrangements. View "In re: B.Cd. & B.Cb." on Justia Law