Justia Juvenile Law Opinion Summaries

In October 2019, Khrysta Turk reported to the Kalispell Police Department that her stepson, L.S., then 13 years old, had inappropriately touched her four-year-old daughter, E.T. L.S. admitted to the inappropriate touching during a police interview. Following the report, L.S.'s mother placed him in various residential treatment facilities for a total of 728 days. The investigation concluded in December 2019, and the matter was referred to the Eleventh Judicial District Court Office of Youth Services in January 2020. The Youth Court decided to monitor L.S.'s treatment informally without initiating formal proceedings.The State filed a formal petition on January 3, 2022, alleging that L.S. committed acts consistent with felony sexual assault. L.S. was appointed counsel, and the District Court set a trial date. L.S. moved for a continuance due to a discovery violation by the State, which delayed the trial. L.S. also filed motions to dismiss for lack of a speedy trial and for the discovery violation. The District Court denied both motions, noting that the case was atypical due to L.S.'s mother's proactive placement in treatment facilities. The trial was rescheduled multiple times, and L.S. eventually admitted to the allegations while reserving the right to appeal the denial of his motions.The Montana Supreme Court reviewed the case and conducted a speedy trial analysis. The Court determined that the delay of 329 days from the filing of the petition to L.S.'s admission was not extraordinary given the serious nature of the allegations. The Court found that the delays were either institutional or due to L.S.'s request for a continuance. L.S. consistently asserted his right to a speedy trial but failed to demonstrate that the delay prejudiced his defense. The Court concluded that no speedy trial violation occurred and affirmed the District Court's denial of L.S.'s motion to dismiss. View "In re L.S." on Justia Law

In June 2021, the defendant, K.D., stole a car with a one-year-old child inside. She was arrested shortly after and found with the stolen items. K.D. admitted to taking the car and knowing the child was inside. She was charged with kidnapping, child abduction, and vehicle theft. K.D.'s defense counsel raised doubts about her competency, leading to evaluations that diagnosed her with a moderate intellectual disability. She was found incompetent to stand trial and was committed to the Porterville Developmental Center for treatment. After being declared competent in August 2022, K.D. requested developmental disability diversion.The Mendocino County Superior Court initially denied K.D.'s request for diversion, citing her lack of ties to the community, her criminal history, and concerns about her ability to comply with diversion requirements. The court also noted that K.D. had never received services from the regional center and had a history of probation violations. Despite acknowledging her developmental disability, the court concluded that her disability was not related to the charged offense and that she would not benefit from diversion.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court found that the trial court had abused its discretion by not properly considering the relationship between K.D.'s developmental disability and the charged offense. The appellate court noted that the trial court failed to ensure that the regional center provided a proper report and diversion plan tailored to K.D.'s needs. The appellate court conditionally reversed the judgment and remanded the case for a new diversion eligibility hearing, instructing the trial court to comply with statutory requirements and consider whether K.D. would benefit from diversion. If K.D. satisfactorily completes diversion, the charges should be dismissed; otherwise, her conviction should be reinstated. View "People v. K.D." on Justia Law

Jonathan Eluterio Martinez-Garcia, a juvenile offender, attacked his 11th-grade English teacher and subsequently pleaded guilty to attempted murder, attempted sexual assault, and battery with the use of a deadly weapon resulting in substantial bodily harm. The district court sentenced him to two consecutive prison terms of 8 to 20 years and a concurrent term of 6 to 15 years, resulting in an aggregate sentence of 40 years with parole eligibility after 16 years. Martinez-Garcia moved to reconsider the sentence, arguing it was illegal and that he was entitled to parole eligibility after 15 years under NRS 213.12135(1)(a). The district court treated the motion as one to correct an illegal sentence and denied it.Martinez-Garcia appealed the district court's decision, contending that his sentence should reflect parole eligibility after 15 years as mandated by NRS 213.12135(1)(a) for juvenile nonhomicide offenders. He argued that the sentence imposed was illegal because it provided for parole eligibility after 16 years, contrary to the statute. The State argued that the sentence complied with the statutes governing the offenses to which Martinez-Garcia pleaded guilty.The Supreme Court of Nevada reviewed the case and held that NRS 213.12135(1)(a) provides for parole eligibility for juvenile nonhomicide offenders after 15 years by operation of law, without requiring resentencing or amendment of the judgment of conviction. The court concluded that the statute does not render a sentence illegal if it otherwise conforms to the sentencing statutes for the offenses committed. Therefore, the court affirmed the district court's order denying Martinez-Garcia's motion to correct an illegal sentence, acknowledging that he will be eligible for parole after 15 years despite the longer parole-eligibility period stated in the judgment of conviction. View "GARCIA VS. STATE" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

J.D., a juvenile defendant, faced multiple charges and challenged his competency to proceed. The juvenile court ordered the Department of Human Services (the "Department") to conduct an in-custody competency evaluation, which found J.D. incompetent but restorable. The court then ordered outpatient restoration services. Subsequently, J.D. was charged with additional delinquent acts, and the court extended its incompetency finding to all cases, ordering the Department to oversee inpatient restoration services and provide periodic status reports.The Department later reassessed J.D.'s competency without a court order and concluded that he had been restored to competency. J.D. moved to strike the Department's report, arguing that the Department lacked the authority to conduct the evaluation without a court order under section 19-2.5-704(2)(c). The juvenile court denied the motion, finding that the Department had the authority to conduct restoration evaluations as part of its responsibility to provide restoration services.The Supreme Court of Colorado reviewed the case and held that the Department's responsibility to provide restoration services under section 19-2.5-704(2)(b) includes the authority to perform restoration evaluations without a court order. The court concluded that restoration evaluations are part of the "services necessary to competency restoration." Therefore, the juvenile court properly accepted and considered the Department's evaluation in finding J.D. restored to competency. The order to show cause was discharged. View "In re People ex rel. J.D." on Justia Law

The Department of Health and Human Services (DHHS) filed a petition in the Wayne Circuit Court to take jurisdiction over a minor, DVL, from the respondent-mother under MCL 712A.2(b)(1) or (2). DVL, who had a history of mental illness, was taken to St. John Hospital after attempting to start a fire and threatening suicide. The hospital cleared DVL for discharge without treatment, recommending intensive outpatient services. The respondent refused to pick up DVL, citing safety concerns for her other children and herself. The trial court denied the petition, finding no evidence of neglect or abuse by the respondent, who had made numerous efforts to seek help for DVL.The Court of Appeals reversed the trial court's decision in a split unpublished decision, holding that jurisdiction was appropriate under both MCL 712A.2(b)(1) and (2). The majority found that the respondent's actions rendered the home environment dangerous for DVL and her other children, making it statutorily unfit. The respondent sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court, in lieu of granting leave to appeal, held that the trial court did not clearly err by refusing to take jurisdiction of DVL under MCL 712A.2(b)(1) or (2). The Court found that the respondent was not "able" to provide necessary care and support for DVL at home due to the danger he posed to himself and others. Additionally, the respondent's refusal to take DVL home was not considered neglectful, as she acted as a reasonably prudent person would under the circumstances. The Court reversed the Court of Appeals decision and remanded the case to the trial court for reinstatement of its order denying DHHS's petition. View "In Re Lange" on Justia Law

A.T. was born in May 2024 and tested positive for amphetamine and methamphetamine, as did her mother, M.T. The mother admitted to drug addiction and using methamphetamine throughout her pregnancy. The San Diego County Health and Human Services Agency (Agency) was notified, and A.T. was placed with a relative caregiver, Gloria T. The father, W.M., had a history of domestic violence and substance abuse issues, and had previously been involved in dependency proceedings for his other children, Y.M. and J.G.The Superior Court of San Diego County found that A.T. was a dependent child under section 300 of the Welfare and Institutions Code and ordered her removal from her mother's custody. The court also found that placing A.T. with her father would be detrimental to her well-being, citing his history of domestic violence, ongoing relationship with the mother, and lack of cooperation with the Agency.The father appealed, arguing that section 361, subdivision (d) should apply, which requires a higher standard of proof for removal, and that there was no clear and convincing evidence to support the finding of detriment. The Agency argued that section 361.2, subdivision (a) applied because the father did not have physical custody of A.T. at the time of disposition and sought to assume custody.The California Court of Appeal, Fourth Appellate District, Division One, concluded that section 361.2 applied because the father was the noncustodial parent seeking custody. The court found clear and convincing evidence supporting the juvenile court's finding that placing A.T. with the father would be detrimental to her safety and well-being. The court affirmed the juvenile court's dispositional order, maintaining A.T.'s placement with the relative caregiver and granting the father liberal unsupervised visitation. View "In re A.T." on Justia Law

A minor, J.H.-M., was adjudicated guilty of second-degree rape by forcible compulsion. The juvenile court imposed a Special Sex Offender Disposition Alternative, including 30-40 weeks of confinement, suspended for a 24-month supervision period. Conditions of supervision included maintaining employment or school enrollment, compliance with treatment requirements, and registration. Although the sentencing judge verbally declined to impose a condition prohibiting sexually explicit material, the written order included this prohibition.J.H.-M. appealed to the Court of Appeals, arguing that the condition prohibiting sexually explicit material was unconstitutionally vague and overbroad. The State initially moved to concede error based on the judge's verbal statement, but Division One of the Court of Appeals denied the motion and directed briefing on the merits. The Court of Appeals affirmed the condition, concluding it was not unconstitutionally vague or overbroad, distinguishing it from a similar condition in a previous case, State v. Padilla.The Supreme Court of the State of Washington reviewed the case. The court held that the condition prohibiting sexually explicit material was not unconstitutionally vague. The court reasoned that the term "sexually explicit conduct" was sufficiently defined by prior case law and the referenced statute, former RCW 9.68A.011(4), which provided specific examples of prohibited acts. The court concluded that the condition provided adequate notice of proscribed conduct and ascertainable standards to prevent arbitrary enforcement. The Supreme Court affirmed the imposition of the condition and the decision of the Court of Appeals. View "State v. J.H.-M." on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law