Justia Juvenile Law Opinion Summaries
Oregon v. C. P.
C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law
In re Kayla W.
Kayla (born in September 2017) came to the attention of the Los Angeles County Department of Children and Family Services (DCFS) after Defendant (mother) was arrested in May 2019. After mother’s arrest, officers found one-year-old Kayla in a motel room, alone. Mother, who was born in California, told an officer and a social worker that she had been living in Nevada since 2017 but had just moved back to California in May 2019 to find work and a place to live. Defendant appealed from an order terminating parental rights to her child, Kayla W. Mother contends that that Nevada’s relinquishment of jurisdiction was conditioned on Kayla being placed with maternal grandfather, so once Kayla was removed from maternal grandfather in December 2021 and placed with another caregiver, the court had to contact Nevada so that it could reassert jurisdiction. Mother argued that the court failed to comply with the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA, Fam. Code, Section 3400, et seq.) The Second Appellate District affirmed. The court first held that mother forfeited the UCCJEA issue because she never objected to Nevada’s declination of jurisdiction, California’s acceptance of jurisdiction, or raised any jurisdictional issue when Kayla was removed from maternal grandfather’s care. Further, the court explained that Nevada did not and could not impose a jurisdictional condition precedent. Moreover, Sections 3429 and 3422 did not require the court to consult Nevada. View "In re Kayla W." on Justia Law
In re Interest of Sayrah P.
The Supreme Court dismissed sixteen-year-old Sayrah P.'s appeal from an order for electronic monitoring and an order for staff secure detention, holding that this appeal lacked a final, appealable order.A juvenile probation officer found that Sayrah qualified for an alternative to detention and sent her home with an order for electronic monitoring. Two days after the initial screening the juvenile court held a hearing and ordered that Sayrah's electronic monitoring continue. Because Sayrah was noncompliant with her electronic monitoring she was ordered a month later to "staff secure" detention. Sayrah appealed. The Supreme Court dismissed the appeal for lack of a final, appealable order, holding that the orders appealed from did not affect a substantial right, and therefore, the orders were not appealable. View "In re Interest of Sayrah P." on Justia Law
New Mexico v. Antonio M.
A jury found that Child-Respondent Antonio M. (Child) committed felony murder, attempted armed robbery, conspiracy to commit armed robbery, child abuse, and aggravated assault with a deadly weapon. The State charged Child as a participant in the fatal shooting of Fabian Lopez (Victim) at Frenger Park in Las Cruces. Uncontested evidence at Child’s adjudicatory hearing established that M.M. and two other participants killed Victim in his car in the course of a drug deal. During opening statements and closing arguments, defense counsel’s theory of the case was that the State could not present sufficient evidence of Child’s participation in the crime and that the robbery and resulting homicide were unplanned and unintended results of a simple drug purchase. Defense counsel did not challenge Child’s presence in the car that transported M.M. to and from the park. On appeal, Child challenged the admission of three in-court identifications under federal and state due process. The Court of Appeals reversed for plain error, finding that the in-court identifications were impermissibly suggestive and thereby violated Child’s due process right to a fair trial under the Fourteenth Amendment of the United States Constitution. The New Mexico Supreme Court determine that identity was not at issue regarding the testimony of the three relevant witnesses and thus that Child’s due process rights were not violated by the relevant in-court identifications. Accordingly, the Supreme Court reversed the Court of Appeals. View "New Mexico v. Antonio M." on Justia Law
Louisiana in the interest of D.W.
The Louisiana Supreme Court granted the State’s application to review the court of appeal’s determination that the State failed to prove that 16-year-old D.W. was the person who entered a sheriff’s vehicle and stole firearms from inside it, and therefore that the evidence was insufficient to support the delinquency adjudication for burglary involving a firearm, La. R.S. 14:62, and theft of a firearm, La. R.S. 14:67.15. After reviewing the record, the Supreme Court found the State presented sufficient evidence that D.W. was a principal, in accordance with La. R.S. 14:24, to these felony-grade delinquent acts regardless of whether he personally entered the vehicle and took the firearms that were inside it himself. Therefore, the Court reversed the ruling of the court of appeal and reinstated the delinquency adjudication and dispositions imposed by the juvenile court, which were then affirmed. View "Louisiana in the interest of D.W." on Justia Law
State v. Erdman
The Supreme Court affirmed the order of the juvenile court granting the State's delinquency petition against Defendant and its motion to waive jurisdiction to allow for Defendant's prosecution as an adult, holding that the juvenile court did not abuse its discretion in granting the waiver and that there was sufficient evidence to support Defendant's conviction.One month after his seventeenth birthday Defendant committed second-degree sexual abuse. The juvenile court issued an order waiving jurisdiction, concluding that there were not reasonable prospectives for rehabilitating Defendant if the juvenile court retained jurisdiction and that the waiver was in the bests interests of Defendant and the community. Defendant was found guilty after a jury trial. The Supreme Court affirmed, holding (1) a rational fact finder could determine beyond a reasonable doubt that Defendant committed second-degree sexual abuse based on the evidence presented; and (2) the juvenile court's waiver decision was supported by the evidence and reasonable. View "State v. Erdman" on Justia Law
Oregon v. B. Y.
While on juvenile parole related to a commitment to Oregon Youth Authority (OYA) in an earlier case, B.Y. was adjudicated to be within the jurisdiction of the juvenile court for interfering with a peace officer. Based on that conduct, the juvenile court imposed a new disposition, which also committed B.Y. to OYA custody, to commence at the conclusion of his existing commitment. B.Y. challenged that order, contending that the juvenile court lacked authority to impose consecutive commitments. A divided panel of the Court of Appeals agreed with B.Y. and reversed the juvenile court. The Oregon Supreme Court reversed the appellate court: “the statutory text neither expressly permits nor expressly prohibits the imposition of consecutive commitments. The statutory scheme does, however, confer broad authority on the juvenile court to fashion appropriate dispositions; that stands in contrast to the criminal code, where courts’ sentencing authority is more circumscribed. Given that contrast, the fact that the legislature did not explicitly provide for consecutive commitments in a circumstance such as this is unsurprising. In light of the wide latitude that the legislature has chosen to give juvenile courts, it is more reasonable to expect that if the legislature had intended to limit the juvenile court’s ability to impose consecutive commitments in this circumstance, the legislature would have indicated as much.” View "Oregon v. B. Y." on Justia Law
In re Jose C.
The juvenile court sustained the petition filed by the Los Angeles County Department of Children and Family Services alleging that Maira H. and Appellant, had a history of engaging in violent physical and verbal altercations in the presence of the children. At disposition the court declared the children dependents of the court, removed them from Appellant’s care and released them to Maira. Appellant appealed the December 2, 2021, findings and orders. Prior to Appellant’s filing of his opening brief on appeal, the juvenile court terminated its jurisdiction and issued custody orders, based on the parents’ mediated agreement, providing for joint legal and physical custody of the children with their primary residence to be with Maira. The custody orders include a parenting plan that specifies a visitation schedule for Appellant and allows for additional visitation as agreed by both parents. Appellant did not appeal the order terminating jurisdiction or the custody orders. The Department contends termination of dependency jurisdiction moots Appellant’s appeal. The Second Appellate District agreed with the Department and dismissed Appellant’s appeal as moot. The court explained that although Appellant is no doubt correct that the jurisdiction findings impacted the custody orders entered by the juvenile court, to provide Appellant with effective relief, the court would have to reverse not only the jurisdiction findings and disposition orders but also the orders terminating jurisdiction and determining visitation. Accordingly, the court explained that because he did not appeal the September 22, 2022, custody and visitation orders, those orders are not now before the court or otherwise subject to appellate review. View "In re Jose C." on Justia Law
T.D. v. State
The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying T.D.'s motion for relief from judgment under Trial Rules 60(B)(6) and 60(B)(8) asserting that his juvenile adjudication should be set aside because his delinquency admission was not knowing, intelligent, or voluntary, holding that there was no error.T.D. agreed to admit to an auto-theft charge. Without informing T.D. of his constitutional rights or confirming that he waived those rights the court accepted T.D.'s admission and granted the delinquency petition. T.D. later filed a motion for relief from judgment, arguing that he was not "informed of a single right on the record." The trial court denied the motion, concluding that his admission was voluntary and knowingly given with adequate assistance of counsel. The Supreme Court reversed, holding that T.D. made a prima facie showing that the trial court failed to comply with the Juvenile Waiver Statute before accepting his admission, and therefore, the trial court abused its discretion by denying T.D.'s motion for relief from judgment. View "T.D. v. State" on Justia Law
In re H.M.
The Supreme Court affirmed the order of the district court denying the motion filed by H.M., a youth held in detention, seeking to dismiss a formal petition brought by the State to adjudicate H.M. as a delinquent youth, alleging one count of misdemeanor resisting arrest and three counts of assault on a police officer, holding that the district court did not err in denying the motion.As grounds to dismiss the petition H.M. argued that the State filed it one day beyond the seven-day time limit for such petitions against detained youths in Mont. Code Ann. 41-5-1401(2). The youth court declined to dismiss the petition, concluding that the State had good cause to file the petition and to detain H.M., outside the seven-day deadline. The Supreme Court affirmed, holding (1) the good cause exception in section 41-5-1401(2) applies to the youth court's decision not to dismiss an untimely petition charging a youth held in detention; and (2) the youth court properly denied H.M.'s motion to dismiss. View "In re H.M." on Justia Law