Justia Juvenile Law Opinion Summaries

The Supreme Court reversed the circuit court’s order denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), holding that Appellant was entitled to a new sentencing hearing based on the Supreme Court’s recent decision in Harris v. State, 547 S.W.3d 64.In 2000, Appellant was convicted of capital murder for a crime that he committed when he was seventeen years old. Appellant received a mandatory sentence of life imprisonment without parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant filed a petition for a writ of habeas corpus. The circuit court granted the writ, vacated Appellant’s sentence, and remanded Appellant’s case for resentencing. Before Appellant’s resentencing hearing was held, the general assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders and extended parole eligibility to juvenile offenders. Thereafter, the circuit court resentenced Appellant to life imprisonment with the possibility of parole after thirty years pursuant to the new penalty provisions of the FSMA. The Supreme Court reversed, holding that because Appellant committed the crime before the effective date of the FSMA, the penalty provisions of the FSMA did not apply to him. View "Howell v. State" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a sentence of life with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), 2017 Ark. Acts 2165, holding that the circuit court erred in applying the FSMA to Appellant’s case.Appellant was sixteen years old when he committed the crimes leading to his convictions for capital murder and theft of property. Appellant received a sentence of life imprisonment without parole for capital murder. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant petitioned for writ of habeas corpus. The circuit court granted the petition, vacated Appellant’s sentence, and remanded for resentencing. Before the circuit court could conduct a Miller hearing, the General Assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders. The State then filed a motion for resentencing under the FSMA. The circuit court relied on the FSMA’s provisions in resentencing Appellant to life with the possibility of parole after thirty years. The Supreme Court reversed, holding that because Appellant’s sentence had been vacated before the FSMA was enacted, the circuit court erred in applying the FSMA to Appellant’s case. The court remanded the case for a Miller hearing. View "Ray v. State" on Justia Law

The Supreme Court reversed Appellant’s sentence of life imprisonment with the possibility of parole imposed in connection with his conviction for one count of capital murder, holding that the circuit court erred in applying the Fair Sentencing of Minors Act of 2017 (FSMA), 2017 Ark Acts 2615, to Appellant’s case.Appellant was fifteen years old at the time of the offense. Appellant was originally sentenced to life without the possibility of parole, but following Miller, the circuit court granted Appellant’s petition for writ of habeas corpus, vacated his sentencing order and remanded the case for resentencing. The circuit court sentenced Appellant to life imprisonment with the possibility of parole after thirty years based on the FSMA, holding that the FSMA applied retroactively. The Supreme Court reversed, holding (1) the circuit court erred when it retroactively applied the penalty and parole provisions of the FSMA when resentencing Appellant; and (2) Appellant was entitled to a hearing to present evidence pursuant to Miller v. Alabama, 567 U.S. 460 (2012), for consideration and sentencing within the discretionary range for a Class Y felony. View "Segerstrom v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant’s petition for writ of habeas corpus, in which Appellant argued that he should be reentenced because his sentence of life imprisonment imposed for an offense committed when he was a juvenile violated the Eighth Amendment pursuant to Miller v. Alabama, 467 U.S. 460 (2012).Appellant pleaded guilty to first-degree murder and other crimes stemming from offenses Appellant committed when he was fifteen years old. Appellant was sentenced to life imprisonment. The Supreme Court affirmed the circuit court’s denial of Appellant’s habeas petition, holding that because a recent statutory amendment by the Arkansas General Assembly created the possibility of parole for Appellant, Appellant’s sentence did not violate the requirements of Miller. View "Lohbauer v. Kelley" on Justia Law

The Supreme Court dismissed the State’s appeal from the circuit court’s use of three nonmodel jury instructions at Appellee’s resentencing hearing, holding that the State failed to demonstrate that the appeal involved the correct and uniform administration of the law or that this was a proper State appeal.Appellee was resentenced after his life sentence was vacated for failure to comport with Miller v. Alabama, 467 U.S. 460 (2012). During the resentencing hearing, the circuit court instructed the jury with three nonmodel instructions based upon the Miller decision. The jury returned a sentence of forty years’ imprisonment, and the circuit court entered an order reducing Appellee’s sentence accordingly. The State appealed, arguing that the use of the nonmodel jury instruction was error. The Supreme Court dismissed the appeal, holding that this was not a proper State appeal. View "State v. Lasley" on Justia Law

Defendant, who was sixteen years old at the time of his arrest, was charged as an adult with robbery and aggravated assault. Defendant was subsequently interviewed by police in connection with an assault of a female. The day after he made a statement, Defendant was charged as an adult with residential burglary, sexual assault in the second degree, and aggravated assault. Defendant filed a motion to suppress the statement he made to police. The circuit court granted the motion to suppress, concluding that Defendant was unable to waive his right to counsel because he was in the custody of the Arkansas Department of Human Services at the time of the interview. The Supreme Court reversed, holding that the circuit court erred in its interpretation of Ark. Code Ann. 9-27-317(g) and therefore erred in granting Defendant’s motion to suppress. View "State v. Griffin" on Justia Law

When he was fifteen years old, Z.L. was charged as an adult of rape. An Extended Juvenile Jurisdiction (EJJ) adjudication order was entered, and Z.L. was committed to the Arkansas Division of Youth Services (DYS). When Z.L. was twenty-one, DYS released him, and Z.L.’s case was set for a hearing in the circuit court to consider imposition of an adult sentence. After a hearing, the circuit court entered an order in the juvenile division finding that Z.L.’s case should be transferred to the criminal division. A second juvenile order was subsequently entered finding that an adult sentence was appropriate. Z.L. was sentenced to twenty-five years in the Arkansas Department of Correction. Z.L. appealed, arguing that the circuit court lacked jurisdiction to impose an adult sentence because he had reached the age of twenty-one before the EJJ review hearing was scheduled and conducted and before the sentencing order was entered. The Supreme Court agreed and reversed and dismissed the case, holding that the circuit court lacked jurisdiction to conduct an EJJ review hearing and impose an adult sentence on Z.L. View "Z.L. v. State" on Justia Law

Appellant N.D. was a juvenile when he was adjudicated delinquent for commission of aggravated robbery and possession of a weapon. After N.D. escaped from the detention center, the State filed a felony information charging N.D. as an adult with capital murder, escape in the first degree, aggravated robbery, theft of property, and second-degree battery. After the Supreme Court reversed the criminal court's denial of N.D.'s motion to transfer his case to the juvenile court, the criminal court transferred N.D.'s case to juvenile court. The juvenile court subsequently entered a decision that N.D. be designated for extended juvenile jurisdiction (EJJ). N.D. appealed, asserting that the criminal court already declined to make such a designation, and because the Supreme Court did not reverse that refusal in N.D.'s first appeal, the issue was decided by law of the case. The Supreme Court affirmed, holding that the Court did not previously reach a decision or provide direction to the criminal court with respect to EJJ designation, nor did the criminal court make a decision regarding EJJ designation, and so the law-of-the case doctrine did not bar the juvenile court from granting the State's motion for an EJJ designation. View "N.D. v. State" on Justia Law

Sixteen-year-old C.B. was charged with the felony offenses of, inter alia, capital murder, aggravated robbery, first-degree escape, and theft of property. C.B. filed a motion to dismiss and to declare Ark. Code Ann. 9-27-318 unconstitutional and a motion to transfer to juvenile court. In challenging the constitutionality of section 9-27-318, C.B. contended that the statute, among other things, violated the separation of powers doctrine by improperly vesting in the local prosecuting attorney power to determine which court has initial jurisdiction over certain classes of juveniles. The circuit court denied both motions. The Supreme Court affirmed, holding (1) section 9-27-318 was constitutional; and (2) the circuit court did not clearly err in denying C.B.'s motion to transfer. View "C.B. v. State" on Justia Law

S.L. was charged with one count of rape in the juvenile division of the circuit court. Before the adjudication hearing, S.L. filed a motion to dismiss for violation of his right to a speedy trial, which the circuit court denied. S.L. then filed another motion to dismiss for lack of a speedy trial, which the circuit court granted. The State appealed. After noting that the State's appeal under these circumstances required the Supreme Court's review for the correct and uniform administration of the criminal law under Ark. R. App. P.-Crim. 3(d) instead of relying on facts unique to the case, the Court dismissed the appeal, as it did not have at issue the correct and uniform administration of justice and, instead, involved the application of the Court's speedy-trial rules to the unique facts of the case. View "State v. S.L." on Justia Law