Justia Juvenile Law Opinion Summaries
In re Raymundo M.
Raymundo M. was charged in juvenile court with assault with a deadly weapon, making a criminal threat, and brandishing a weapon after he raised a switchblade-like knife head-high and chased another minor while orally threatening him. The juvenile court found the charges and certain of the enhancement allegations true, declared Raymundo a ward of the court, and placed him with his mother under the supervision of the probation department. On appeal, Raymundo contended: (1) insufficient evidence supported the true finding on the assault count because he never got within striking distance of the victim or made stabbing or slashing motions with the knife; (2) the juvenile court failed to expressly declare whether it was treating the "wobbler" assault count as a felony or a misdemeanor, as required by Welfare and Institutions Code section 702; and (3) the court erred by imposing duplicative punishment on the criminal-threat and assault counts, in violation of Penal Code section 654. Finding no reversible error, the Court of Appeal affirmed. View "In re Raymundo M." on Justia Law
Roberts v. State
The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Defendant's petition for postconviction relief, holding that, under Minn. Stat. 260B.245, subd. 1(b), delinquency adjudications may be deemed "felony convictions" for the purpose of the statutory definition of a crime of violence. Defendant was charged with possession of a firearm by an ineligible person, which required proof that Defendant had been convicted of a crime of violence. Defendant pled guilty to the offense, admitting that he had been adjudicated delinquent for committing fifth-degree possession of a controlled substance. The district court accepted the plea and placed Defendant on probation. Defendant later filed a petition for postconviction relief, asserting that his juvenile delinquency adjudication failed to satisfy the definition of a "crime of violence" because, under section 260B.245, a delinquency adjudication cannot be deemed a "conviction of crime." The district court denied postconviction relief. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase "felony convictions," as used in the statutory definition of crime of violence, includes a juvenile delinquency adjudication for felony-level offenses listed in Minn. Stat. 624.712, subd. 5; and (2) Defendant provided an adequate factual basis for his guilty plea. View "Roberts v. State" on Justia Law
IDJC v. Dudley
In 2016, John Doe was cited for petit theft. Doe’s disposition hearing was held, and the magistrate court committed Doe to the custody of Idaho Department of Juvenile Corrections (“IDJC”). the magistrate court ordered Doe’s father, Dennis Dudley, to reimburse IDJC for expenses incurred in caring for and treating Doe pursuant to Idaho Code section 20-524(1). Doe and Dudley appealed the reimbursement order to the district court. The district court, acting in its intermediate appellate capacity, affirmed. Doe and Dudley timely appealed the district court’s decision. The Idaho Supreme Court dismissed the appeal, finding the reimbursement order against Dudley was not a final appealable order. View "IDJC v. Dudley" on Justia Law
Hairston v. Idaho
James Hairston was sentenced to death after a jury convicted him of two counts of first-degree murder in connection with the deaths of William and Dalma Fuhriman. Hairston was about nineteen and a half when he killed the Fuhrimans. In this, his fourth post-conviction petition, Hairston argued his sentence was unconstitutional because: (1) he was under the age of twenty-one at the time of the offense; and (2) the trial court failed to give adequate consideration to the mitigating factors that had to be considered with youthful defendants. The district court dismissed Hairston’s first claim after holding that he failed to show that evolving standards of decency prohibited imposing the death penalty for offenders between the ages of eighteen and twenty-one. The court dismissed Hairston’s second claim after finding that there was no basis to extend the special sentencing considerations that have been specifically limited to juvenile defendants under eighteen to those under twenty-one. Finding no reversible error in those judgments, the Idaho Supreme Court affirmed. View "Hairston v. Idaho" on Justia Law
Raines v. Georgia
In 2013 when he was 17 years old, Dantazias Raines was sentenced to life in prison without the possibility of parole (“LWOP”) for malice murder. The Georgia Supreme Court affirmed Raines' convictions and sentences in part, reversed Raines' convictions for misdemeanor obstruction of a police officer, and vacated his sentence in part. On remand, Raines filed a motion for a jury to make the requisite determination under Veal v. Georgia, 784 SE2d 403 (2016). The trial court denied his motion and certified its order for immediate review. The Supreme Court granted Raines' request for interlocutory review to consider whether a defendant facing a sentence of life without parole for an offense committed when he was a juvenile had a constitutional right to have a jury (as opposed to a judge) make the requisite determination of whether he was “irreparably corrupt” or “permanently incorrigible.” Raines argued in favor of having a jury make the determination prior to imposition of a LWOP sentence; the State argued a defendant did not have a right under the Sixth Amendment for the jury to make the "specific determination" outlined in Veal. The Supreme Court held a defendant convicted of committing murder as a juvenile did not have a federal constitutional right to have a jury determine, in accordance with Veal and the Sixth Amendment, whether he was irreparably corrupt or permanently incorrigible such that he may be sentenced to LWOP, thereby affirming the trial court. View "Raines v. Georgia" on Justia Law
In re J.P.
In this extended-jurisdiction juvenile proceeding, the Supreme Court reversed the judgment of the court of appeals dismissing the juvenile's appeal, holding that the court of appeals had jurisdiction to hear the appeal. The district court gave John P., a juvenile offender, both a juvenile sentence and an adult sentence. The adult sentence was stayed on the condition that John substantially comply with the terms of the juvenile sentence and not commit a new offense. A week before John's conditional release supervision ended, the State moved to revoke his juvenile sentence and impose the adult one, citing several alleged violations of conditional-release rules. The district court found that John had violated the terms of conditional release and imposed the adult sentence. The court of appeals dismissed John's appeal, determining that it lacked jurisdiction because Kan. Stat. Ann. 38-2380(b) doesn't authorize the appeal of a later order imposing an adult sentence in an extended-jurisdiction juvenile proceeding. The Supreme Court reversed, holding that Kan. Stat. Ann. 38-2347(e)(4) gives a juvenile offender who is the subject of an extended jurisdiction juvenile prosecution all the rights an adult defendant would have, which includes the right to appeal an adverse judgment such as the one in this case. View "In re J.P." on Justia Law
In re A.A.
A.A., born in February 2003, was first adjudicated delinquent and placed at Woodside, a secure treatment facility for juveniles, in September 2016. He was placed back in his home in the continued custody of the Department for Children and Families (DCF) in December 2017. In 2018, A.A. was charged in the criminal division, with one count of assault and robbery, injury resulting, and one count of providing false information to a police officer. Shortly thereafter, a delinquency petition alleging larceny was filed against A.A. in the family division. While these cases proceeded, A.A. was administratively held at Woodside in connection with the earlier, unrelated delinquency case. In this appeal, the issue presented for the Vermont Supreme Court's review centered on whether the statutory timeline for adjudicating the merits of A.A.'s delinquency petition while held in a secure treatment facility applied to the delinquency petition where there was no secured-facility placement order because A.A. had already been placed at a secure facility pursuant to a prior, separate delinquency petition. Because the Supreme Court concluded the statutory timeline set forth in 33 V.S.A. 5291(b) did not apply in such situations, the Court rejected A.A.'s call for dismissal of the petition on appeal and vacation of the secure-facility placement order that had been issued under a different petition. The Court affirmed the family division’s order adjudicating A.A. delinquent for having committed assault and robbery. View "In re A.A." on Justia Law
State v. A.I.
The Supreme Judicial Court affirmed the order of the juvenile court placing A.I. in the custody of the Department of Health and Human Services, holding that the juvenile court correctly applied the preponderance of the evidence standard when it determined whether to place A.I. in the custody of the Department. On appeal, Mother argued that the matter should be remanded to the juvenile court so that findings can be addressed under a clear and convincing standard rather than a preponderance of the evidence standard. The Supreme Judicial Court disagreed, holding that A.I.'s dispositional hearing fell on the less-intrusive end of the continuum and that the juvenile court did not err when it applied the preponderance of the evidence standard in the proceedings below. View "State v. A.I." on Justia Law
In re S.J.
In October 2018, S.J. (born September 2001) consumed alcohol and drove. He veered off the road and hit a parked car and a fence. Responding officers observed signs of intoxication. A breath test showed S.J.’s blood-alcohol level was 0.12%. A petition under Welfare and Institutions Code 602(a) alleged: misdemeanor driving under the influence; misdemeanor driving while having a blood-alcohol level of 0.08% or more; and misdemeanor driving without a license. In February 2019, the juvenile court found S.J. not suitable for informal supervision, commenting “a standard term in adult-land for a DUI is search and seizure for alcohol. … it’s particularly important when we have a minor . . . whose … mother has allowed ... the minor to consume alcohol. … I just don’t see how, in a DUI with a .12 and a minor who also smokes marijuana, we can effectively supervise and ensure rehabilitation without a search and seizure clause, which is foreclosed in an informal probation setting.” The court sustained two allegations, dismissing the driving without a license allegation, declared S.J. a ward of the court, and directed the Probation Department to supervise him at home. The court imposed a $75 restitution fine, a $390 fine for violation of Vehicle Code section 23152, and $1,355 in penalties. The court of appeal affirmed the denial of informal supervision but remanded for recalculation of the penalties, most of which were inapplicable in this noncriminal proceeding. View "In re S.J." on Justia Law
In re Brownlee
Terrence Brownlee was 19 years old when he was sentenced to 17 years to life in state prison for second degree murder committed with a firearm. The Court of Appeal held that Brownlee was not entitled to a youth offender parole hearing, because the statutory framework's plain language, Penal Code sections 3051, 3051.1, and 4801, does not afford him one. The court explained that, within this statutory framework, if a prisoner's first parole hearing is not a youth offender parole hearing, then the prisoner does not receive a youth offender parole hearing. Such prisoners are still entitled to have the board consider the diminished culpability of youth as compared to adults, the hallmark features of youth, and any subsequent growth and maturity. View "In re Brownlee" on Justia Law