Justia Juvenile Law Opinion Summaries

Defendant Benny Townes was convicted of multiple sexual offenses against his biological daughters, Jane Doe 1 and Jane Doe 2. Jane Doe 1, who was 16 years old, was raped and impregnated by the defendant. Jane Doe 2, who was 13 and 14 years old at the time, was raped, sodomized, and subjected to lewd acts by the defendant. The defendant admitted to having sexual intercourse with Jane Doe 1 but argued that it was consensual and not against her will.The Superior Court of Riverside County found the defendant guilty on all counts, including forcible rape, incest, lewd acts with a minor, and sodomy. The court sentenced him to 150 years to life in prison. The defendant appealed, contending that there was insufficient evidence to support the finding that he raped Jane Doe 1 by means of force or duress, and therefore, his convictions on counts 1 and 2 should be reversed. He also argued that the multiple victim enhancement allegations should be reversed if counts 1 and 2 were overturned.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case and affirmed the judgment. The court held that substantial evidence supported the finding of duress, which can be purely psychological. The defendant had instilled in Jane Doe 1 the belief that he was the son of God and that disobeying him would result in divine retribution. This psychological coercion was sufficient to constitute duress under Penal Code section 261, subdivisions (a)(2) and (b)(1). The court concluded that the threat of divine retribution, as taught by the defendant, was enough to uphold the convictions for forcible rape. View "People v. Townes" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" on Justia Law

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

The State of Wyoming filed a petition against MF (Mother) and JF (Father) on June 22, 2020, alleging neglect of their minor children, JF and TF. Following a shelter care hearing, the juvenile court removed the children from the home and placed them in foster care. After a disposition hearing, the children remained in the custody of the Department of Family Services (the Department), with a permanency plan of family reunification. On January 19, 2024, after an evidentiary permanency hearing, the juvenile court changed the permanency plan to adoption.The juvenile court found that the Department had made reasonable efforts to reunify the family, but these efforts were unsuccessful. The court noted that Mother had made some progress but ultimately failed to consistently address the children's needs and safety concerns. The court also found that the children's best interests were served by changing the permanency plan to adoption, given their progress in foster care and the lack of stability and safety in Mother's care.The Wyoming Supreme Court reviewed the case and affirmed the juvenile court's decision. The court held that the juvenile court did not abuse its discretion in changing the permanency plan to adoption, as the Department had made reasonable efforts at reunification, which were unsuccessful. The court also found that the juvenile court's decision to cease reunification efforts with Mother was supported by Wyoming law, which allows for discontinuation of such efforts when they are inconsistent with the permanency plan.Additionally, the Wyoming Supreme Court held that Mother's due process rights were not violated by the denial of a continuance of the permanency hearing or by the juvenile court's evidentiary rulings. The court found that Mother had adequate notice and opportunity to be heard, and the juvenile court's decisions were within the bounds of reason. The court also declined to adopt Mother's request for a change in procedures to require compliance with the Wyoming Rules of Evidence in evidentiary permanency hearings. View "In the Interest of: JF v. The State of Wyoming" on Justia Law

A juvenile was involved in an altercation at the Barnstable District and Juvenile Court, where he was charged with disorderly conduct and assault and battery. The incident was captured on video, showing the juvenile and the victim engaging in a physical fight. The juvenile had a prior continuance without a finding (CWOF) after admitting to sufficient facts for an assault and battery charge.The Juvenile Court adjudicated the juvenile delinquent on both charges and sentenced him to one year of probation for each. The juvenile appealed, arguing that the court lacked jurisdiction over the disorderly conduct charge because a CWOF after an admission to sufficient facts should not count as a prior offense under G. L. c. 119, § 52. The Appeals Court did not review the case as it was transferred to the Supreme Judicial Court.The Supreme Judicial Court held that a CWOF entered after an admission to sufficient facts is sufficient to establish a first offense under § 52. Therefore, the Juvenile Court had jurisdiction over the disorderly conduct charge. The court also found that the evidence was sufficient to support the juvenile's adjudications of delinquency for both disorderly conduct and assault and battery. The court affirmed the adjudications, concluding that the juvenile did not act in self-defense and that his actions met the criteria for disorderly conduct. View "Commonwealth v. Fayad F." on Justia Law

J.M.H. pleaded guilty to disorderly conduct in juvenile court in 2022. The trial court judge issued a disposition order with certain conditions, which J.M.H. violated multiple times. In October 2022, the judge issued a warrant for her arrest. J.M.H.'s lawyer challenged the warrant, arguing it did not comply with JuCR 7.16, the rule for issuing juvenile warrants. The trial court denied the motion, and J.M.H. appealed.The appeal was reviewed by the Court of Appeals. By that time, the trial court judge who issued the warrant had been appointed to the Court of Appeals and sat on the panel reviewing his own decision. The panel dismissed the appeal, stating the order was not appealable under RAP 2.2(a). J.M.H. sought discretionary review, arguing it was reversible error for the judge to sit on the appellate panel.The Supreme Court of the State of Washington reviewed the case. The court held that a judge cannot review an appeal of a decision they made as a trial court judge in the same case, citing In re Murchison and In re Dependency of A.N.G. The court found that this violated due process and required automatic reversal. The Supreme Court reversed the decision and remanded the case to the Court of Appeals for further proceedings. View "State v. J.M.H." on Justia Law

Jennifer Harmon’s son, N.J., died by suicide while residing at the Bruce Normile Juvenile Justice Center (BNJJC) under the care of the Second Judicial Circuit of Missouri. Harmon filed a lawsuit seeking damages for her son’s death, including various 42 U.S.C. § 1983 and state wrongful death claims against the Second Circuit, several named defendants from both the Second Circuit and BNJJC, Preferred Family Healthcare (PFH), and several named defendants from PFH. All defendants filed motions to dismiss for failure to state a claim.The United States District Court for the Eastern District of Missouri granted the Second Circuit and Government Defendants’ motion to dismiss. The court found that the claims against the Second Circuit were barred by the Eleventh Amendment, the § 1983 claims against the Government Defendants were barred by qualified immunity, and the state tort claims against the Government Defendants were barred by official immunity. Harmon appealed these immunity judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of Harmon’s claims against the Second Circuit, holding that the Second Circuit is not a “person” amenable to suit under § 1983 and is entitled to Eleventh Amendment immunity, which Missouri has not waived. The court also affirmed the dismissal of Harmon’s § 1983 claims against the Government Defendants, concluding that the Government Defendants were entitled to qualified immunity because Harmon failed to show that any constitutional violation was clearly established. Lastly, the court affirmed the dismissal of Harmon’s state tort claims against the Government Defendants, holding that the Government Defendants were entitled to official immunity under Missouri law because Harmon failed to plead both the existence of a department-mandated policy and a breach of that policy. View "Harmon v. Second Judicial Circuit of the State of Missouri" on Justia Law

G.R. lived with her mother and had no contact with her alleged father, R.R. In 2017, G.R. was hospitalized and diagnosed with disruptive mood dysregulation disorder. The Los Angeles Department of Child and Family Services became involved when the mother failed to secure necessary mental health services for G.R. The mother did not have contact information for R.R. The juvenile court initially found R.R. to be G.R.'s alleged father, later amending the order to reflect this accurately. R.R. was incarcerated for domestic violence and had an extensive criminal history. The court denied services to R.R. and ordered no visits until he contacted the Department.In May 2018, the juvenile court removed G.R. from her mother's custody and placed her with a maternal aunt. In November 2020, R.R. expressed a desire to have a relationship with G.R., but did not follow through with setting up visits. In January 2023, R.R. filed a deficient section 388 petition, which the juvenile court denied. By June 2023, G.R. had spoken with R.R. by phone but was not ready for in-person visits. In September 2023, the juvenile court appointed G.R.'s caregiver as her legal guardian, ordered monitored visits for R.R., and terminated its jurisdiction.The California Court of Appeal, Second Appellate District, reviewed the case. The court dismissed R.R.'s appeal of the juvenile court's order requiring monitored visits, stating that as an alleged father, R.R. could not show he was aggrieved by the order. The court emphasized that an alleged father has no rights to custody, reunification services, or visits unless he establishes paternity and achieves presumed father status. R.R. did not establish paternity, and thus had no standing to appeal the visitation order. View "In re G.R." on Justia Law

The case involves a father (H.B.) appealing a juvenile court's disposition order that declared his two sons dependents of the court, placed them in the custody of their mother, and provided family maintenance services to the mother and supportive services to the father. The San Francisco Human Services Agency filed a petition alleging that the minors were at substantial risk of harm due to the father's substance abuse and provision of drugs to one of the children. The father contested the findings, arguing that the juvenile court applied an incorrect legal standard and that there was insufficient evidence to support its findings.The juvenile court sustained the petition's allegations, assumed jurisdiction over the children, and ordered their placement with the mother. The court found that the father posed a substantial danger to the children due to his substance abuse and poor parenting decisions, including providing drugs to his son. The court applied section 362, subdivision (c), rather than section 361, subdivision (c), concluding that the children were not removed from a custodial parent since they remained with their mother.The California Court of Appeal, First Appellate District, reviewed the case. The court determined that the juvenile court erred in applying section 362(c) instead of section 361(c), as the children were effectively removed from the father's custody. The appellate court found substantial evidence supporting the juvenile court's finding of substantial danger to the children if returned to the father's care. However, it concluded that there was insufficient evidence to support the finding that reasonable efforts were made to prevent or eliminate the need for removal. The appellate court reversed the disposition order and remanded the case for a new disposition hearing, instructing the juvenile court to make its decision based on the facts existing at the time of the new hearing. View "In re H.B." on Justia Law

A minor child, Baby Girl R., was abandoned by her mother, S.R., shortly after birth. S.R. gave birth in a homeless encampment and was using methamphetamines daily. Baby Girl R. tested positive for the drug and exhibited withdrawal symptoms. S.R. was placed on an involuntary psychiatric hold due to paranoia, delusions, and aggression. After being discharged, S.R. left Baby Girl R. at the hospital and returned to the encampment. The Department of Family and Children’s Services initiated dependency proceedings, and Baby Girl R. was placed in protective custody. Despite diligent efforts, the Department could not locate S.R.The juvenile court placed Baby Girl R. in foster care and ordered reunification services for S.R., despite her unknown whereabouts. The court found that S.R.’s location was unknown despite reasonable efforts to locate her. Baby Girl R. appealed, arguing that the court should have bypassed reunification services under Welfare and Institutions Code section 361.5, subdivision (b)(1). While the appeal was pending, the juvenile court terminated reunification services for S.R. at the six-month review hearing and placed Baby Girl R. with her maternal grandparents.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that the appeal was moot due to the termination of reunification services but exercised discretion to address the merits. The court concluded that section 361.5, subdivision (b)(1) does not mandate bypassing reunification services when a parent’s whereabouts are unknown despite a diligent search. The juvenile court has discretion to grant or deny reunification services in such cases. The appellate court found no error in the juvenile court’s decision to order reunification services for S.R. and affirmed the disposition order. View "In re Baby Girl R." on Justia Law