Justia Juvenile Law Opinion Summaries
Louisiana v. Williams
On March 25, 2013, the 18-year-old defendant Clifford Williams shot and killed 15-year-old Ralphmon Green in the 2100 block of Allen Street in New Orleans. The victim was struck by bullets four times and defendant continued to fire at him after he fell to the ground. Eight shell casings found at the crime scene matched a semiautomatic handgun that was later found at defendant’s residence. Several eyewitnesses to the shooting testified that the victim was unarmed. Before trial, the defense was prohibited from introducing evidence of the victim’s juvenile arrest for illegal carrying of a weapon. At trial, the defense unsuccessfully attempted to introduce other evidence of the victim’s character. Specifically, the defense sought to introduce a photograph that depicted the victim holding a gun, evidence that the victim had threatened defendant on social media, and testimony of a witness that the victim had previously threatened defendant. In rejecting defendant’s claim on appeal that the district court erred in excluding this evidence, the court of appeal found that defendant failed to introduce appreciable evidence of a hostile demonstration or overt act on the part of the victim at the time of the offense charged, as required by La.C.E. art. 404(A)(2)(a). Defendant contended the court of appeal erred because testimony of an eyewitness constituted appreciable evidence of an overt act by the victim, and the district court overstepped its bounds in evaluating the credibility of that witness to find the evidence was not appreciable because the witness was not credible. To this point, the Louisiana Supreme Court agreed. However, the Court found the evidence was otherwise inadmissible, and therefore affirmed the conviction and sentence. View "Louisiana v. Williams" on Justia Law
Louisiana in the interest of D.T.
Louisiana charged D.T. with aggravated battery committed with a firearm, and sought to divest the juvenile court of jurisdiction and to prosecute D.T. as an adult pursuant to Louisiana Children’s Code Article 305(B)(2)(j). In response, D.T. filed a motion with the juvenile court to declare La. Ch.C. art. 305(B)(2)(j) unconstitutional. The juvenile court granted D.T.’s motion. On the state's application to the Louisiana Supreme Court, the Supreme Court concurred with the trial court that La. Ch.C. art. 305(B)(2)(j) was indeed unconstitutional, concluding the legislature exceeded its constitutional authority in creating an exception allowing divesture of juvenile court jurisdiction for a child charged with aggravated battery committed with a firearm, where that charge is not among the crimes enumerated in La. Const. art. V, sec. 19. View "Louisiana in the interest of D.T." on Justia Law
People v. Sepulveda
Defendant, who was 18 years old at the time of the attempted murders and 21 years old when he committed murder, seeks remand of his cause for a hearing under People v. Franklin (2016) 63 Cal.4th 261, because his counsel stipulated, without his consent, to limit information regarding youth-related mitigating factors to a written submission following the sentencing hearing. The Court of Appeal held that counsel's stipulation to file the Franklin package after the sentencing hearing and without presentation of live testimony did not violate defendant's constitutional rights. The court also held that defendant's ineffective assistance of counsel claim should be presented in a petition for writ of habeas corpus. Accordingly, the court affirmed the judgment, ordering a correction on the abstract of judgment to reflect the sentence. View "People v. Sepulveda" on Justia Law
In re: H.R.
On September 20, 2010, at age of 13 appellant, H.R., was adjudicated delinquent for indecent assault of a complainant less than 13 years of age. Appellant was placed on official probation and, pursuant to Section 6352 of the Juvenile Act, was ordered to undergo inpatient treatment at a sex offender residential treatment facility. Appellant remained in treatment when he turned 20 in February 2017 and he was assessed pursuant to Section 6352, the results of which found that involuntary treatment at a sex offender residential treatment facility pursuant to the Court-Ordered Involuntary Treatment of Certain Sexually Violent Persons Statute (Act 21) was still necessary. On January 4, 2018, following a hearing, a trial court denied appellant's motion to dismiss and granted the petition for involuntary treatment, determining appellant was an sexually violent delinquent child (SVDC) and committing him to one year of mental health treatment. On appeal, appeal, appellant argued: (1) Act 21 was punitive in nature, and this its procedure for determining whether an individual was an SVDC was unconstitutional; and (2) retroactive application of amendments to Act 21 made effective in 2011, was also unconstitutional. The Pennsylvania Supreme Court determined the superior court correctly determined the relevant provisions of Act 21 were not punitive, were constitutional, thus, affirming the trial court's order. View "In re: H.R." on Justia Law
State v. R.R.S.
The Supreme Court reversed the judgment of the court of appeals reversing the decision of the trial court denying R.R.S.'s motion to withdraw his plea of "true" to allegations that he sexually assaulted his younger brother when he was thirteen years old, holding that a child's legal inability to consent to sex does not render the child legally incapable of committing aggravated sexual assault. Based on R.R.S.'s admissions and plea, the trial court found him delinquent. Before the disposition hearing, R.R.S. unsuccessfully filed a motion to withdraw his plea and requested a new trial. The court of appeals reversed the denial of the motion, ruling that because R.R.S. was not adequately informed when he entered his plea about his potential defense that he could not have committed aggravated sexual assault because he could not legally "consent to sex" the trial court erred in denying the motion. The Supreme Court reversed the court of appeals' decision and reinstated the trial court's judgment, holding that the court of appeals erred in holding that R.R.S.'s lack of knowledge of his inability to consent to sex required the trial court to grant his motion to withdraw his plea and for a new trial. View "State v. R.R.S." on Justia Law
People v. Wilkes
Wilkes was convicted for the attempted murder of Christopher and related crimes. The court of appeal affirmed the conviction but modified the judgment to strike an enhancement for a prior one-year prison term for a grand theft conviction and award presentence conduct credits. The court upheld other enhancements and rejected Wilkes’s challenge to the sufficiency of the evidence that he intended to kill Christopher and that the attempted murder was premeditated and deliberate. There was evidence that Wilkes purposefully fired a gun into the front passenger window of a car, knowing Christopher was in the driver’s seat, and that he fired a subsequent shot at Christopher after Christopher exited the car. The court also rejected Wilkes’s equal protection challenge to a statutory provision rendering youth offenders sentenced pursuant to the Three Strikes Law (Pen. Code 667(b)–(j), 1170.12), such as Wilkes, ineligible for youth offender parole hearings. (section 3051(h).) View "People v. Wilkes" on Justia Law
In re S.E.
The Court of Appeal affirmed the district court's restitution order against defendant, then age 16, who admitted to making criminal threats in violation of Penal Code 422. The court held that the juvenile court erred by applying the presumption of causality contained in Penal Code section 1202.4, subdivision (f)(4)(A) to victim restitution ordered under section 730.6. However, the court rejected defendant's claim that his conduct was not shown to be a substantial factor in an injury to the so-called derivative victims. The court also held that the juvenile court properly imposed interest on the amount of restitution. View "In re S.E." on Justia Law
In re a Minor
The Supreme Judicial Court vacated the order of the juvenile court committing a juvenile for substance use disorder treatment pursuant to Mass. Gen. Laws ch. 123, 35, holding that the juvenile was committed on insufficient evidence. After a hearing, the juvenile court judge committed the juvenile for ninety days for treatment. The Supreme Judicial Court vacated the commitment order, holding (1) appeals from an order of commitment pursuant to Mass. Gen. Laws ch. 123, 35 are not moot solely because the individual is no longer committed; (2) taking into account a juvenile's youth necessarily is required as part of the individualized assessment demanded by such petitions; (3) it was not clearly erroneous to find that the juvenile had a substance use disorder; (4) the evidence in the record was insufficient to support a finding of imminent and "very substantial risk of physical impairment or injury" as required by Mass. Gen. Laws ch. 123, 1; and (5) due process requires a judge to consider less restrictive alternatives in all commitment hearings for substance use disorder treatment. View "In re a Minor" on Justia Law
Coats v. New Haven Unified School District
When E.D. was 17 years old, a high school teacher began engaging in sex with her in his classroom. The situation was discovered after several months. The teacher admitted engaging in sexual intercourse with E.D. 10-20 times while she was a minor. The principal had previously disciplined the teacher for inappropriate contact with a student but the conduct had not been reported to authorities; no steps were taken to monitor the teacher’s contact with other female students. E.D. brought claims against the teacher for sexual abuse, against the school defendants for negligence and breach of statutory duties in failing to adequately supervise teachers and protect students, and against all the defendants for intentional and negligent infliction of emotional distress; her foster mother joined in the claims of intentional and negligent infliction of emotional distress. They alleged that they were not required to present a claim to the School District under the Government Claims Act (Gov. Code 810) due to the exemption for claims of sexual abuse of a minor, section 905(m). The District had enacted its own claim presentation requirement, purportedly overriding section 905(m) The court of appeal reversed the dismissal of E.D.’s causes of action. The Legislature has consistently expanded the ability of childhood sexual abuse victims to seek compensation but it is not clear that it intended to provide relatives the same rights as direct victims. View "Coats v. New Haven Unified School District" on Justia Law
Pedroza v. State
The Supreme Court approved the court of appeal's decision to uphold Defendant's sentence and disapproved of several recent court decisions to the extent they held that resentencing is required for all juvenile offenders serving a sentence longer than twenty years without the opportunity for early release based on demonstrated maturity and rehabilitation, holding that Defendant in this case did not establish a violation of Miller v. Alabama, 567 U.S. 460 (2012). Defendant was charged with the first-degree murder of her mother committed when she was age seventeen. Defendant pled guilty to second-degree murder in exchange for a forty-year sentence. Defendant later challenged her sentence as cruel and unusual punishment under Miller. The trial court denied Defendant's petition. The court of appeal affirmed but certified conflict with several decisions of other district courts. The Supreme Court affirmed, holding that because Defendant did not establish that her sentence was a life sentence or the functional equivalent of a life sentence Defendant failed to establish that her sentence violated the Eighth Amendment, Miller, or its equivalent on a juvenile homicide offender whose youth has not been taken into account at sentencing. View "Pedroza v. State" on Justia Law