Justia Juvenile Law Opinion Summaries
In the Matter of April S.
An Alaska Native teenage minor affiliated with the Native Village of Kotzebue (Tribe) was taken into custody by the Office of Children’s Services (OCS) and placed at a residential treatment facility in Utah. She requested a placement review hearing after being injured by a facility staff member. At the time of the hearing, the minor’s mother wanted to regain custody. At the hearing the superior court had to make removal findings under the Indian Child Welfare Act (ICWA), as well as findings authorizing continued placement in a residential treatment facility under Alaska law. At the hearing, the minor’s Utah therapist testified as a mental health professional. The minor, as well as her parents and the Tribe, objected to the witness being qualified as an ICWA expert, but the superior court allowed it. The minor argued the superior court erred in determining that the witness was qualified as an expert for the purposes of ICWA. Because the superior court correctly determined that knowledge of the Indian child’s tribe was unnecessary in this situation when it relied on the expert’s testimony for its ICWA findings, the Alaska Supreme Court affirmed. View "In the Matter of April S." on Justia Law
Sanford. v. Michigan
Plaintiff Davontae Sanford filed suit against the state of Michigan, seeking compensation under the Wrongful Imprisonment Compensation Act (WICA). Another man confessed to the crimes committed in 2007 to which plaintiff had pled guilty when he was 15 years old: four counts of second-degree murder and carrying a firearm during the commission of a felony. In 2008, plaintiff was sentenced to concurrent terms of 37 to 90 years in prison for the murder convictions, plus a consecutive two-year term for the felony-firearm conviction, with credit for the 198 days he spent in the Wayne County Juvenile Detention Facility. After an investigation into the other man’s confession and with the stipulation of the prosecutor, the circuit court vacated plaintiff’s convictions and sentences on June 6, 2016, and plaintiff was released from the Michigan Department of Corrections June 8, 2016. Defendant admitted that plaintiff was entitled to $408,356.16 in compensation for the 8 years and 61 days he spent in a state correctional facility pursuant to the WICA’s damages formula set forth in MCL 691.1755(2)(a), but defendant disputed whether plaintiff was entitled to $27,124.02 in compensation for the 198 days he spent in local detention. The Court of Claims held that the time plaintiff spent in local detention was not compensable under the WICA, and it awarded plaintiff $408,356.16. Plaintiff appealed as of right, and the Court of Appeals affirmed. The Michigan Supreme Court concurred with the appellate court that the WICA did not authorize compensation for the time plaintiff spent in detention before he was wrongfully convicted of a crime, and affirmed that court's judgment. View "Sanford. v. Michigan" on Justia Law
Interest of K.V.
In early 2019, Devils Lake Police Officer Gilbertson was dispatched on a report of a possibly impaired driver. Gilbertson pulled the vehicle over and as he reached the back of the vehicle, the vehicle fled the scene. Gilbertson pursued; another officer attempted to deploy road spikes. The vehicle avoided the spikes and zig-zagged through a field until it became stuck in the snow. When the occupants did not leave the vehicle, Gilbertson approached the vehicle, reached in, put it in park, smelling a strong odor of marijuana. After removing and arresting the driver, officers removed passenger, K.V. Another responding officer, Officer Engen, Engen did a pat down search of K.V. and found drug paraphernalia, a bong, and a bag of meth in K.V.’s jacket. Engen averred he patted down K.V. to search for weapons as a safety issue and to look for illegal drugs. K.V. was alleged to be a delinquent child, charged with possession of a controlled substance and possession of drug paraphernalia. K.V. filed a motion to suppress, contending there was no exception for the warrantless search and the search was prohibited by the Fourth Amendment. The juvenile court denied the motion to suppress on the record, finding: “There was marijuana in the vehicle. You were in the vehicle [K.V.]. Once [the officers] establish that they had the smell of marijuana in the vehicle, they had the right to search you and they found the methamphetamine in the coat pocket that you were wearing.” The court denied K.V.’s renewed motion to suppress at the adjudication hearing. K.V. was adjudicated a delinquent child for possession of methamphetamine and possession of drug paraphernalia. Although the juvenile court court received testimony about the officers’ concern for their safety and the smell of marijuana, the North Dakota Supreme Court found the juvenile court did not make specific findings on the reasonableness of the pat down or subsequent search. "It did not identify which exception to the warrant requirement justified the search in its conclusions of law. We are unable to understand the court’s reasoning for its decision and are left to speculate as to the law and facts the court relied on in denying the motion to suppress." Judgment was reversed and the matter remanded for reconsideration of the suppression order. View "Interest of K.V." on Justia Law
Ulla U. v. Commonwealth
The Supreme Judicial Court held that a juvenile court judge has authority to hear a motion to dismiss as part of a transfer hearing after arraignment and that a juvenile does not have an automatic right of appeal under Mass. Gen. Laws ch. 211, 3 where the motion is denied. A juvenile argued that the prosecutor improperly delayed bringing criminal charges against her until after her nineteenth birthday and filed a motion to dismiss for prosecutorial delay. The juvenile court judge denied the juvenile's motion to dismiss, determining that the motion should be heard after the transfer hearing was complete and any subsequent complaint was issued in an adult court. The juvenile filed a petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied the petition, and the juvenile was arraigned. The Supreme Judicial Court remanded the case, holding (1) with certain exceptions, a juvenile court judge generally has no authority to dismiss a complaint prior to arraignment; and (2) a juvenile has no automatic right to an interlocutory appeal from the denial of a motion to dismiss for bad faith or inexcusable delay. View "Ulla U. v. Commonwealth" on Justia Law
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