Justia Juvenile Law Opinion Summaries
California v. Humphrey
In 2011, Dominick Humphrey pled guilty to four counts of robbery (counts 2, 3, 4 and 24). For three of these counts (counts 2, 3, and 4), Humphrey admitted that he used a deadly weapon (a knife) during the commission of the offenses, and used a firearm during the commission of one of the counts (count 24). Humphrey also admitted that he was 16 years old when he committed the crimes within the meaning of Welfare and Institutions Code section 707. The trial court sentenced Humphrey to prison for 19 years. Five years into Humphrey's sentence, an employee of the California Department of Corrections and Rehabilitation (CDCR) wrote a letter to the superior court, stating that the abstract of judgment "may be in error, or incomplete[.]" In 2018, the trial court clarified that Humphrey was sentenced to 15 years for count 24 and the associated firearm enhancement and consecutive 16-month terms for counts 2, 3, and 4 (including their deadly weapon enhancements). An amended abstract of judgment was issued showing a sentence of 19 years in state prison. Thereafter, Humphrey moved to strike the firearm enhancement under Senate Bill No. 620. The trial court denied the motion because Humphrey's conviction became final before the enactment of Senate Bill No. 620. Appellate counsel filed a "Wende" brief, indicating that he had not been able to identify any arguable issue for reversal on appeal, but asked the Court of Appeal to review the record for error as Wende mandated. In reviewing the record, the Court discovered an issue to be briefed, and the parties were requested to brief whether the trial court erred in finding Humphrey ineligible for relief under Senate Bill 620 after the trial court acted to correct the abstract of judgment. Find that the trial court only made plain how the original sentence should have appeared on the amended abstract of judgment, the Court of Appeal determined Humphrey did not file a notice of appeal following the original 2011 sentence. His case became final in 2011. Senate Bill 620 took effect January 1, 2018, and Humphrey's was not entitled to retroactive application of the law to his sentence. Therefore the trial court did not err in denying his motion for resentencing. View "California v. Humphrey" on Justia Law
Smith v. May
The Supreme Court affirmed the judgment of the court of appeals denying Appellant's pro se petition for a writ of habeas corpus, holding that the court of appeals correctly denied relief. Appellant was sixteen years old when four delinquency complaints were filed in juvenile court. The cases were transferred to adult court where Appellant was convicted of five felony counts and sentenced to an aggregate prison term of sixteen years. Appellant later filed this habeas corpus petition alleging that the juvenile court did not fully comply with the procedures for transferring jurisdiction to the adult court because it did not timely notify his father of a hearing in one of the cases that led to the transfer of some of the charges. The court of appeals denied the writ. The Supreme Court affirmed, holding that the juvenile court's failure to provide timely notice was not a defect that deprived the adult court of subject matter jurisdiction. View "Smith v. May" on Justia Law
People v. M.B.
People v. Dueñas (2019) 30 Cal.App.5th 1157, does not apply to a mandatory minimum juvenile restitution fine. The Court of Appeal held that the trial court's order requiring M.B. to pay a $100 restitution fine does not violate his due process rights. To the extent that Dueñas purports to state a rule of California criminal procedure, the court questioned whether the Court of Appeal, as opposed to the Supreme Court, has the authority to do so. The court explained that it was not bound by a sister appellate court opinion and it was obligated to follow the California Constitution, Article 6, 13. Therefore, the court concluded that a $100 mandatory juvenile restitution fine did not result in a miscarriage of justice. View "People v. M.B." on Justia Law
Commonwealth v. Preston P.
The Supreme Judicial Court remanded this matter to the juvenile court for further proceedings, holding that, for revocation of pretrial probation in the juvenile court based on a new criminal offense, the Commonwealth must prove that there is probable cause to believe that the juvenile committed the offense. At issue in this case was the standard of proof and procedural requirements necessary for the revocation of pretrial probation in the juvenile court. The Supreme Judicial Court held (1) Mass. Gen. Laws ch. 276, 58B does not govern the revocation of pretrial probation of a juvenile; (2) to revoke a juvenile's pretrial probation based on a new criminal offense, a judge must find probable cause that the juvenile committed the offense, and all other violations must be proved, at an evidentiary hearing, by a preponderance of the evidence; and (3) for a revocation of a juvenile's pretrial probation, due process requires notice of the alleged violations, the opportunity to be heard, and a judicial finding that the juvenile committed the violation. View "Commonwealth v. Preston P." on Justia Law
People v. L.W.
After L.W. was charged in a juvenile wardship petition with committing sexual battery against two minor females, the juvenile court issued temporary restraining orders against defendant as to the two alleged victims under Welfare and Institutions Code, section 213.5 and rule 5.630 of the California Rules of Court. The Court of Appeal held that because the People presented no evidence of an emergency or other urgency and made no attempt to give defendant prior notice of their intent to seek the temporary restraining orders, the juvenile court erred in issuing those orders without notice. However, the court held that the juvenile court did not err in issuing the pre-adjudication three-year restraining order, because the order was a reasoned and reasonable response to defendant's conduct and the other relevant facts of the case. Furthermore, the order was entirely consistent with the public policy objectives underlying the juvenile delinquency laws generally and section 213.5 specifically. Accordingly, the court affirmed the three-year restraining order. View "People v. L.W." on Justia Law
Andrew M. v. Superior Court of Contra Costa County
Shortly before turning 18 Andrew committed an armed robbery; his accomplice shot and killed a police officer. After his conviction, Judge Brady sentenced Andrew to life in prison without the possibility of parole (LWOP), plus 24 years. The court of appeal reversed one special circumstance. On remand, Judge Brady sentenced Andrew to LWOP plus 24 years. After a second remand following the U.S. Supreme Court's Miller decision (2012), Judge Brady imposed LWOP plus 23 years, finding Andrew’s actions “were not those of an irresponsible or impulsive child," nor the product of peer pressure, coercion, or surprise and finding no realistic chance of rehabilitation. The court of appeal affirmed. The California Supreme Court returned the case with directions to consider whether legislation rendering juvenile LWOP defendants eligible for parole suitability hearings mooted Andrew’s challenge. While Andrew’s appeal was pending Proposition 57 eliminated a prosecutor’s ability to “direct file” charges in criminal court against minors of a certain age. These minors may be tried in criminal court only after the juvenile court conducts a transfer hearing to consider specific factors. The court rejected Andrew’s LWOP challenge but concluded he was entitled to a Proposition 57 hearing. The superior court granted the prosecution's motion to assign that hearing to Judge Brady. The court of appeal rejected a mandamus petition. A conditional reversal and limited remand for a Proposition 57 transfer hearing are not a “new trial” under Code of Civil Procedure section 170.61, which permits parties in civil and criminal actions to move to disqualify an assigned trial judge based on an allegation that the judge is prejudiced against the party. View "Andrew M. v. Superior Court of Contra Costa County" on Justia Law
In re M.T.
During a physical fight between M.T. and the victim during which the victim’s cell phone and case dropped to the ground, another student picked up and stole the victim’s cell phone and case. The Contra Costa County District Attorney filed a section 602 petition, alleging M.T. had committed a misdemeanor battery against a fellow student on school property. The juvenile court placed M.T. on informal supervision for six months, with standard conditions of probation, stating that M.T. and her parents, and a coparticipant minor, would be jointly and severally liable to pay restitution under Welfare and Institutions Code section 654.2. Before a contested restitution hearing, the probation department filed a report stating it had received a victim impact and claim statement seeking restitution of $989 for the cell phone, cash located in the cell phone case, and copays for an emergency room visit and for three therapy visits. M.T. challenged the court ordering her “to pay restitution for a theft she was not involved in nor charged with.” The court of appeal dismissed, reasoning that the order is neither a judgment nor an order after judgment for which an appeal is authorized under section 800. View "In re M.T." on Justia Law
Goodwin v. Iowa District Court for Davis County
The Supreme Court affirmed Defendant's sentence imposed in connection with his guilty plea to second-degree murder, holding that where Defendant received an individualized sentencing hearing that addressed the Miller/Lyle/Roby factors Defendant's challenge to his sentence did not constitute a proper motion to correct an illegal sentence. Defendant was sixteen years old when he fatally shot his father. After an individualized sentencing hearing the district court imposed a fifty-year prison sentence with a twenty-year mandatory minimum before parole eligibility and recited its consideration of the sentencing factors. Defendant later filed a motion to correct an illegal sentence and for appointment of counsel, alleging that the district court failed properly to apply the factors set forth in Miller v. Alabama, 567 U.S. 460 (2012), State v. Lyle, 854 N.W.2d 378 (Iowa 2014), and State v. Roby, 897 N.W.2d 127 (Iowa 2017). The district court denied the motion. The Supreme Court affirmed, holding (1) a motion claiming the district court misapplied the Miller/Lyle/Roby factors does not constitute a challenge to an illegal sentence with a concomitant statutory right to counsel; (2) Defendant's challenge to his sentence did not constitute an attack on an illegal sentence; and (3) the district court acted within its authority in sentencing Defendant to the twenty-year mandatory minimum. View "Goodwin v. Iowa District Court for Davis County" on Justia Law
In re William M.W.
The Social Services Agency alleged that the children were exposed to domestic violence and substance abuse. The court declared the minors to be juvenile court dependents, removed them from parents’ care, and ordered reunification services. The Agency recommended termination of reunification and referral for selection of a permanent plan. The matter was set for a contested hearing. The parents' attorneys moved to compel discovery, seeking an order that copies of discovery be provided by the Agency to both parents at no cost. The Agency refused, arguing that it had fulfilled its discovery obligations by making discovery available for inspection in accordance with its usual protocol. Parents’ counsel was allowed to take pictures of documents or to otherwise copy them using their own supplies without charge. The Agency argued that requiring it to provide free discovery would violate separation of powers principles and constitute a gift of public funds. The juvenile court denied the motion, to avoid “acting in excess of its authority.” The court of appeal reversed. While no court rule, statute, or constitutional principle requires the order sought by parents, should a circumstance arise where an indigent parent’s meaningful access to the judicial process is impaired by discovery requirements, the juvenile court has the authority to fix the time, place, and manner of discovery upon terms and conditions as will serve the ends of justice. The court remanded to allow the court to exercise its discretion to decide whether any further discovery order is necessary in this case. View "In re William M.W." on Justia Law
In re Anthony L.
Five teenagers attacked a 61-year-old man in his driveway. The incident was captured on security cameras. Minor’s teacher identified him from photographs. San Francisco Police Sergeant Smith contacted Minor’s mother, stating that he was investigating a crime and needed to meet with Minor, age 15. Officer Martinez, who spoke Spanish, accompanied Smith to the home. Martinez’s body camera recorded the events. Mother led them to Minor’s bedroom, where he was sleeping, and stayed in the room. Smith handed Minor a “Juvenile Know Your Rights” form and told Minor, “I’m going to read you your rights just because you’re a juvenile… you’re not under arrest.” When asked if he understood each statement, Minor answered “Yes.” Minor was largely unresponsive but eventually said that he hit the victim. Smith then placed Minor under arrest. The court of appeal affirmed a juvenile court order placing Minor on probation. Although police must arrange for the youth to consult with counsel before interrogating a 15-year-old in custody, (Welf. & Inst. Code 625.6(a)), the statute does not provide for exclusion of the minor’s statements as a remedy. Minor’s constitutional rights were not violated. Minor knowingly waived his Miranda rights and was not subjected to deception or trickery. The court struck, as vague, a probation condition, requiring Minor to “[c]onsult with the Probation Officer without hesitation when you are in need of advice.” View "In re Anthony L." on Justia Law