Justia Juvenile Law Opinion Summaries

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A defendant who was sentenced to 66 years to life for violent sex offenses he committed at age 17 is not entitled to youth offender parole consideration under Penal Code section 3051 on federal and California constitutional equal protection grounds.The Court of Appeal found that a rational basis exists for treating one strike offenders such as defendant differently from other youthful offenders entitled to the benefit of the statute, applying the reasoning and analysis of the court in People v. Williams (2020) 47 Cal.App.5th 475, review granted July 22, 2020, S262229. In this case, defendant was convicted of four counts of forcible rape, one count of forcible oral copulation, and one count of first degree robbery. The court explained that defendant is not similarly situated to those who do not commit violent sex crimes, and his exclusion from youth offender parole consideration is rationally related to a legitimate penal interest. View "People v. Moseley" on Justia Law

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The Supreme Judicial Court held that 120 Code Mass. Regs. 200.08(3)(c) (regulation), which concerns parole eligibility for inmates sentenced to a prison term that runs consecutive to a life sentence, is contrary to the plain terms of the statutory framework governing parole and is thus invalid.Plaintiffs, two inmates who were serving life sentences for murders committed when they were juveniles, sought declaratory relief invalidating the regulation. The superior court granted summary judgment in favor of the parole board, finding the regulation to be valid. The Supreme Judicial Court reversed, holding that by exempting sentences consecutive to a life sentence from the process often referred to as the "aggregation rule," the regulation contravenes the plain meaning of Mass. Gen. Laws ch. 127, 130 and 133. View "Dinkins v. Massachusetts Parole Board" on Justia Law

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The Supreme Judicial Court vacated the orders of the juvenile court judge requiring the Department of Youth Services (DYS) to credit the time that two youthful offenders spent detained in DYS custody prior to being adjudicated against their postadjudication confinement, holding that youthful offenders are not entitled to preadjudication detention credit like prisoners.Defendants were indicted as youthful offenders and held without bail in DYS custody. The judge committed each defendant to DYS custody until the age of twenty-one and ordered DYS to credit the time each spent detained in DYS custody prior to being adjudicated. The Supreme Judicial Court vacated the orders requiring preadjudication credit, holding that Mass. Gen. Laws ch. 218, 59 does not authorize a juvenile court judge to order preadjudication detention credit for youthful offenders pursuant to Mass. Gen. Laws ch. 279, 33A, which applies to criminal defendants. View "Commonwealth v. Terrell" on Justia Law

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A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication.The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings. View "Doe v. Shenandoah Valley Juvenile Center Commission" on Justia Law

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Defendants Harquan Johnson and KeAndre Windfield were each convicted of one count of murder and one count of attempted murder, and assault with a semi-automatic firearm, along with gun discharge and gang enhancement allegations as to the murder and attempted murder counts. The charges arose from the shooting of two members of their own gang, the Ramona Blocc Hustlas, resulting in the death of one of them. Both defendants were sentenced to prison for 90 years to life. They appealed raising various claims. In the original opinion, filed August 2014, the Court of Appeal affirmed both defendants' convictions, but reversed Johnson’s sentence pursuant to California v. Gutierrez, 58 Cal.4th 1354 (2014), because, as a juvenile at the time of the crime, his sentence of 90 years to life was the functional equivalent of a term of life without possibility of parole and we directed other modifications of the sentence and abstracts of judgment. In November 2014, the California Supreme Court denied both defendants’ petitions for review, but, on its own motion, issued a grant-and-hold of review as to defendant Johnson, for consideration pending review in In re Alatriste, S214652, In re Bonilla, S214960, and California v. Franklin, S217699. In May 2016, the Supreme Court issued its decision in Franklin (63 Cal.4th 261 (2016)), and retransferred his case to the Court of Appeal with directions reconsider Johnson’s sentence. The appellate court issued a second opinion in September 2016, affirming those portions of the original opinion pertaining to issues not subject to the grant and hold, and reconsidered Johnson's sentence. Defendants again successfully petitioned for review; the Supreme Court retransferred the cases to the Court of Appeal with directions to reconsider the case in light of California v Canizales, 7 Cal.5th 591 (2019), and California v. Perez, 3 Cal.App.5th 612 (2016). Judgment was modified per direction, and defendants again appealed. In April 2020, the Supreme Court again transferred this matter to the appellate court to reconsider in light of Senate Bill 620 (Stats. 2017, ch. 682). After reconsideration, the Court of Appeal affirmed both defendants' convictions. As to Windfield, a hearing was warranted for both defendant and the State to make an accurate record of defendant’s characteristics and circumstances at the time of the offense, and to amend his abstract of judgment fix a date error. As to Johnson, the case was remanded for the limited purpose of a fitness hearing: if not fit, Johnson's convictions were to be reinstated; if the juvenile court found it would not have transferred Johnson to be tried as an adult, it should treat his convictions as juvenile adjudications and impose an appropriate "disposition" within its discretion. In addition, the court could exercise its discretion whether to strike or dismiss any of the firearm enhancements within the meaning of Senate Bill No. 620. View "California v. Windfield" on Justia Law

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The Fifth Circuit affirmed the district court's imposition of a 460 month term of imprisonment based on defendant's conviction for first-degree murder under 18 U.S.C. 1111(b). While a person convicted of first-degree murder under section 1111(b) "shall be punished by death or by imprisonment for life," a defendant who was under the age of eighteen at the time of the offense, such as defendant, cannot be sentenced to death or mandatory life imprisonment under Miller v. Alabama, 567 U.S. 460, 479 (2012) (holding mandatory life without parole unconstitutional for juveniles), and Roper v. Simmons, 543 U.S. 551, 575 (2005) (holding the same for the death penalty.) In this case, the district court resolved the constitutional defect by severing section 1111(b)'s punishment provision for first-degree murder, determining that the statute-as-modified authorizes imprisonment "for any term of years or for life."The court rejected defendant's contention that the district court unconstitutionally fashioned a new punishment for first-degree murder committed by juveniles, violating the Due Process Clause's notice requirement and separation-of-powers doctrine. Rather, the court concluded that it is appropriate to sever as necessary, and that excising the mandatory minimum nature of the life sentence is all that is needed to satisfy the constitutional issue for juveniles under section 1111. In this case, the district court's remedy complies with Roper and Miller, functions independently, and is consistent with Congress's clear intent to criminalize "the unlawful killing of a human being with malice aforethought." The court also rejected defendant's assertion that the district court violated the Due Process Clause and Federal Rule of Criminal Procedure 11 by failing to specify his potential sentencing range at his plea hearing. The court explained that defendant's plea hearing demonstrates that the district court properly notified him of the consequences of a guilty plea, and therefore defendant's plea was knowing and voluntary. View "United States v. Bonilla-Romero" on Justia Law

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This case relates to the consent decree incorporating the Flores Agreement, a 1997 settlement agreement between the United States and a class of all minors subject to immigration detention. The Agreement established nationwide standards for the detention, release, and treatment of minors by U.S. immigration authorities. The Agreement, by its own terms, terminates after the government's publication of final regulations implementing the Agreement. In 2019, the government issued final regulations represented as implementing, and thus terminating, the Agreement. The district court then concluded that the new regulations, on the whole, were inconsistent with the Agreement, enjoining the regulations from taking effect and denying the government's motion to terminate the Agreement.The Ninth Circuit held that the provisions of the new regulations relating to unaccompanied minors are consistent with the Agreement except to the extent that they require ORR to place an unaccompanied minor in a secure facility if the minor is otherwise a danger to self or others and to the extent they require unaccompanied minors held in secure or staff-secure placements to request a hearing, rather than providing a hearing to those minors automatically unless they refuse one.The panel also held that some of the regulations regarding initial detention and custody of both unaccompanied and accompanied minors are consistent with the Agreement and may take effect. However, the remaining new regulations relating to accompanied minors depart from the Agreement in several important ways. Therefore, the panel affirmed the district court's order enjoining those regulations. The panel further held that the district court correctly concluded that the Agreement was not terminated by the adoption of the regulations. Finally, the panel held that the district court did not abuse its discretion in denying the government's motion to terminate the Agreement, as the government has not demonstrated that changed circumstances, such as an increase in family migration, justify terminating the Agreement's protections. View "Flores v. Rosen" on Justia Law

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E.P., a minor in a juvenile delinquency proceeding, challenged a July 2020, decision by respondent Yolo County Superior Court, which denied his motion to physically appear in juvenile court in the presence of the judge at court hearings. Petitioner claimed the court’s decision, as well as certain temporary local rules (Super. Ct. Yolo County, Temporary COVID-19 Local Rules) issued by the court in response to the COVID-19 pandemic, conflicted with Welfare and Institutions Code section 679 and the emergency rules related to COVID-19 adopted by the Judicial Council and contained in appendix I of the California Rules of Court. The Court of Appeal concluded that, consistent with section 679 and the case law interpreting it, the emergency rules required a court obtain a minor’s consent before conducting a hearing in a juvenile delinquency proceeding remotely. Accordingly, the respondent superior court erred in denying petitioner’s motion to physically appear in court at his juvenile hearings. To the extent the court’s temporary local rules required all hearings in juvenile delinquency proceedings be conducted remotely absent a finding of good cause, the rules were in conflict with both section 679 and the emergency rules. View "E.P. v. Superior Court" on Justia Law

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Defendant appealed the trial court's decision sustaining a petition for first degree burglary with a person present, contending that the trial court erred in denying his Brady/Johnson motion for an in camera review and discovery of the arresting officer's confidential personnel file. In People v. Galan (2009) 178 Cal.App.4th 6, the Court of Appeal upheld the denial of a motion to inspect the confidential personnel file of a police officer.The court held that there, as here, there was no good cause for discovery. In this case, defendant cites no authority, and the court has found none, that a Brady/Johnson motion may be used as a fishing expedition to disclose confidential personnel files that have no logical link to the 911 call, the arrest, the charges, a defense, or the impeachment of a witness. Accordingly, the court affirmed the trial court's judgment. View "People v. M.C." on Justia Law

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The Supreme Court held that Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal.A jury found Defendant guilty of aggravated murder and other offenses stemming from a fatal shooting when Defendant was seventeen years old. The trial court sentenced Defendant to life imprisonment with parole eligibility after thirty years for the aggravated murder offense. On appeal, Defendant argued that his sentence violated the Eighth and Fourteenth Amendments. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal; and (2) consistent with this Court's decision in State v. Long, 8 N.E.3d 890 (Ohio 2014), a trial court must separately consider the youth of a juvenile offender as a mitigating factor before imposing a life sentence under Ohio Rev. Code 2929.03 even if that sentence includes eligibility for parole. View "State v. Patrick" on Justia Law