Justia Juvenile Law Opinion Summaries

Articles Posted in Civil Procedure
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A juvenile, K.C., was charged with two serious misdemeanors: carrying dangerous weapons and possession of marijuana. As K.C. was 17 at the time of the incident, the juvenile court had initial jurisdiction. However, after K.C. turned 18, the State filed a petition to waive the juvenile court's jurisdiction. In preparation for the waiver hearing, K.C. hired a forensic psychologist, Dr. Tracy Thomas, to conduct an evaluation. K.C. requested the State to cover Dr. Thomas's fees, which were estimated to be $7,990. The juvenile court initially authorized the fees but later set a limit of $4,590, deeming the full amount unreasonable. K.C. filed a motion for additional expert fees, which was denied by the juvenile court. K.C. then filed a petition for a writ of certiorari, arguing that the juvenile court acted illegally by not properly determining whether the requested expert fees were reasonable.The Supreme Court of Iowa agreed with K.C. that the juvenile court's order was not supported by substantial evidence. The court noted that three of the four reasons the juvenile court initially cited for deeming the full fee unreasonable were no longer relevant. The court also found that the juvenile court failed to provide any explanation for why it declined to increase the fee award or reconsider its denial. The Supreme Court of Iowa concluded that the juvenile court's reasoning was based on an erroneous application of law and thereby abused its discretion.The Supreme Court of Iowa sustained the writ of certiorari, vacated the juvenile court's orders denying K.C.'s requests for additional expert fees, and remanded the matter for entry of an order authorizing the full $7,791.20 in expert fees for Dr. Thomas's work. View "K.C. v. Iowa District Court for Polk County" on Justia Law

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The case revolves around Taylor C., who was declared a ward of the court at the age of 14. After his wardship ended, Taylor successfully moved to dismiss his wardship petitions under the Welfare and Institutions Code section 782. He then sought to seal his juvenile court records. However, the juvenile court denied his request, citing his prior adjudications for committing forcible lewd conduct, which made his records ineligible for sealing under section 781, subdivision (a)(1)(F). Taylor appealed, arguing that the dismissal of his wardship petitions erased the adjudication of his offenses as if they never existed.The lower court had granted Taylor's motion to dismiss his wardship petitions, finding that the interests of justice and Taylor's welfare warranted dismissal and that he was no longer in need of rehabilitation. However, it denied his motion to seal his juvenile court records, citing the prohibition in subdivision (a)(1)(F) of section 781 on sealing records relating to his forcible lewd conduct offenses.The Court of Appeal of the State of California First Appellate District Division Three affirmed the lower court's decision. The court held that the dismissal of a juvenile petition under section 782 does not obviate the prohibition on sealing records under section 781, subdivision (a)(1)(F) in cases involving certain delineated offenses. The court found that Taylor's records were ineligible for sealing because section 782, subdivision (e) provides that dismissal of a petition does not alone constitute a sealing of records and section 781, subdivision (a)(1)(F), precludes sealing due to the forcible lewd conduct offenses. View "In re Taylor C." on Justia Law

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In 2022, a delinquency petition was filed against G.W., a 17-year-old, alleging that he had committed acts that would be considered theft and criminal trespass if committed as an adult. G.W. admitted to one allegation of theft and one allegation of criminal trespass. After G.W. went missing and was later found in Mississippi, he was returned to Indiana for his dispositional hearing. The juvenile court rejected G.W.'s request for home detention and ordered wardship of G.W. to the Department of Correction (DOC). However, the court's dispositional order did not include specific findings to support G.W.'s commitment, as required by statute.The Court of Appeals affirmed the juvenile court's decision but acknowledged that the order failed to comply with the applicable statutory requirements. The panel remanded the case for an amended dispositional order which includes the written findings and conclusions required by the statute. After the Court of Appeals had delivered its decision, but before it had certified that decision, the juvenile court issued an amended dispositional order which included the required statutory findings.The Indiana Supreme Court held that when a juvenile court fails to enter the requisite findings of fact in its dispositional order, an appellate court should neither affirm nor reverse. Instead, the proper remedy is to remand the case under Indiana Appellate Rule 66(C)(8) while holding the appeal in abeyance. This process adheres to the applicable statutory requirements, preserves the distinct roles played by trial courts and appellate courts, and (in some cases) justifies the cost of juvenile detention. The court remanded the case to the juvenile court for entry of its amended dispositional order. View "G.W. v. State" on Justia Law

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The case involves a father, J.L., who appealed against orders that declared his children, P.L and L.L, to be dependents of the juvenile court and placed them with their mother, H.T. J.L. also contested the condition of his visitation rights, arguing that the court improperly delegated its visitation authority to the children. The San Diego County Health and Human Services Agency maintained that J.L. forfeited the issue by not raising it at the lower court level.The parents had a child welfare history dating back to 2019, with multiple referrals regarding J.L. physically or emotionally abusing the children. The parents divorced in 2023, and shared custody until an incident occurred where J.L. allegedly punched P.L. The Agency then obtained protective custody warrants for the children. The court placed the children with their mother and ordered liberal supervised visitation for J.L., considering the children's wishes on whether visits would go forward. This order was not objected to by J.L's counsel.The Court of Appeal, Fourth Appellate District Division One State of California concurred with the Agency and affirmed the lower court's orders. It held that J.L. forfeited his right to contest the visitation orders by failing to raise the issue at the lower court level. Furthermore, even if the issue was not forfeited, the appellate court found no abuse of discretion by the lower court in allowing the children to decline visiting J.L. The court explained that it was J.L.’s responsibility to request a specific change to the visitation order if he was unhappy with the children's refusal to visit him. View "In re P.L." on Justia Law

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This case is an appeal from the Superior Court of Placer County, California. The appellant, J.S., challenges the denial of his motion to dismiss his juvenile wardship petition and seal all related records under California Welfare and Institutions Code section 786. The court had determined that J.S. was ineligible for such relief because he had a new finding of wardship during his probation period, interpreting the statute as categorically precluding relief in such a situation.The case hinged on the interpretation of section 786, subdivision (c)(1), which stipulates that satisfactory completion of probation occurs if the person has no new findings of wardship or conviction for a felony offense or a misdemeanor involving moral turpitude. J.S. argued that this provision should only preclude relief if the new finding of wardship was for a felony offense or a misdemeanor involving moral turpitude. The court agreed with J.S.'s interpretation.The court concluded that the juvenile court had erred in its interpretation of the statute by denying J.S.'s motion based on any new finding of wardship during the probation period. The court found that the statutory language and legislative history supported J.S.'s argument that relief under section 786 is not categorically precluded when there is a new finding of wardship during the period of probation that was not based on a felony offense or a misdemeanor offense involving moral turpitude.The case was remanded for further proceedings for the juvenile court to reconsider J.S.'s motion under the correct interpretation of the statute. View "In re J.S." on Justia Law

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This case involves a person identified as Tony R., who was committed to the Reaching Into Successful Endeavors (RISE) program for a term of 11 years or until he reached the age of 25, with a baseline term of four years. This was following his involvement in serious offenses, including attempted murder and second-degree robbery. Tony appealed from the juvenile court's denial of his request to reduce his baseline term of confinement at his first six-month review hearing. He argued that the court lacked the authority to deny his request or, in the alternate, that it had abused its discretion.At the six-month review, the court evaluated Tony's progress in relation to his rehabilitation plan, which included a series of programs and treatments aimed at addressing his needs. Tony had been participating in these programs successfully and was performing well academically. Despite this, the court denied his request for a reduction in his baseline term.The Court of Appeal of the State of California, First Appellate District, affirmed the juvenile court's decision. The appellate court found that the juvenile court did not abuse its discretion in denying Tony's request for a reduction in his baseline term. The appellate court noted that the law gives juvenile courts discretion to reduce the baseline term but does not require it to do so, and that the juvenile court's decision was within the bounds of reason under the applicable law and the relevant facts. View "In re Tony R." on Justia Law

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In this case, the United States Court of Appeals for the Fifth Circuit dismissed as moot the appeal by the Louisiana Governor and other state officials challenging a district court’s preliminary injunction. Originally, the district court had ordered the state officials to remove juvenile offenders from the Bridge City Center for Youth at West Feliciana (BCCY-WF) and barred them from housing juveniles at the facility in the future. The state officials appealed this decision. However, the preliminary injunction automatically expired under the Prison Litigation Reform Act (PLRA) before the appeal could be resolved, rendering the appeal moot. The Court of Appeals also vacated the district court's underlying order because it was moot. The Court noted that the appeal did not meet the exception for mootness for issues that are capable of repetition but evade review, as the state officials could not show that similar future injunctions would evade review or that they would again be subject to the same action. View "Smith v. Edwards" on Justia Law

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In the case under review, the defendant, Paradise Burkhead, was charged with crimes committed when she was a juvenile. Under the juvenile transfer statute in effect at the time of her hearing, her case was transferred from the Jefferson District Court to the Jefferson Circuit Court for adult prosecution because she was over fourteen years old and had committed a felony with a firearm. After a new juvenile transfer statute came into effect, which eliminated the mandatory transfer requirement, Burkhead sought to have her case transferred back to the district court for a second transfer hearing. The circuit court granted her motion, despite the Commonwealth's objection. The Commonwealth appealed this decision, and the Court of Appeals affirmed. The Supreme Court of Kentucky reversed the lower courts' decisions.The Supreme Court of Kentucky held that the Commonwealth's interlocutory appeal was proper and that the circuit court erred by ordering a second transfer hearing. The court found that the interlocutory appeal was justified under KRS 22A.020(4) because it was adverse to the Commonwealth's interests, the proceedings were not suspended, the appeal followed normal rules and procedures, and the Attorney General affirmed that appellate review was important to the correct and uniform administration of the law.As for the retroactive application of the new juvenile transfer statute, the court held that "proceedings" in KRS 446.110 refers to the distinct phases of a case. Therefore, the court must apply the current procedural law governing the particular procedural phase being undertaken. The court held the transfer hearing was a completed phase of the criminal process, and nothing in KRS 446.110 suggested that a court must repeat a completed phase to comply with a procedural amendment. Therefore, the circuit court erred in remanding the case for a second transfer hearing. The case was remanded to the Jefferson Circuit Court for further proceedings. View "COMMONWEALTH V. BURKHEAD" on Justia Law

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In the case before the Supreme Court of the State of Oregon, the parents of three children under the jurisdiction of the Department of Human Services (DHS) appealed the juvenile court's decision to change the placement preference for their children from the mother's home to foster care. However, while the appeal was pending in the Court of Appeals, the juvenile court issued additional decisions determining that substitute care was still the appropriate placement preference for the children. The Court of Appeals dismissed the appeal as moot due to these subsequent judgments, ruling that it could not conclude without speculation that the challenged judgments would have a practical effect on the parents' rights. The Supreme Court of the State of Oregon reversed the decision of the Court of Appeals, finding that the Court of Appeals had incorrectly placed the burden on the parents to prove that the appeal was not moot, rather than on DHS to prove that it was. However, the Supreme Court found that the juvenile court's subsequent dismissal of the dependency cases altogether did render the appeals moot, as the parents and the children were no longer wards of the court and the original substitute-care placement determination no longer had a practical effect on the parties. The Supreme Court therefore dismissed the appeals as moot. View "Dept. of Human Services v. T. J. N." on Justia Law

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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