Justia Juvenile Law Opinion Summaries

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" 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

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also contended the trial court had jurisdiction to resentence Bagsby and erred by ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed section 1170(d) despite amendments and that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and outside juvenile court jurisdiction. The court also found the stay order would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. View "P. v. Bagsby" on Justia Law

In this case, the defendant was accused of sexually assaulting three minors between 2007 and 2009. The police obtained a search warrant and found child pornography on the defendant's computers, including an encrypted file they could not access. The defendant was indicted on multiple counts, including sexual conduct against a child and possession of child pornography. He posted bail and was released but was later remanded to jail for allegedly posting a blog that intimidated a witness.The trial court assigned counsel and experts to assist the defendant, who later chose to represent himself. During the trial, the defendant's daughter testified about a recorded conversation in which one of the victims allegedly recanted her accusations. The prosecution used recorded jail phone calls to challenge the daughter's testimony, revealing that the defendant had discussed trial strategies with her. The jury found the defendant guilty of one count of sexual conduct against a child and all child pornography counts but deadlocked on other charges. The defendant entered an Alford plea to the deadlocked counts.The Appellate Division affirmed the judgment, and the New York Court of Appeals reviewed the case. The primary issue was whether the defendant's right to present a defense was violated by the prosecution's monitoring of his jail phone calls. The Court of Appeals held that the defendant's right to present a defense was not violated. The court noted that the defendant had ample time to prepare his defense while out on bail and had other means to communicate with witnesses. The court also found that the defendant's request to proceed pro se was unequivocal and that the trial court had conducted a proper inquiry into the risks of self-representation. The order of the Appellate Division was affirmed. View "People v Dixon" on Justia Law

A juvenile court judge in Hamilton County, Ohio, presided over the trial of a thirteen-year-old accused of felonious assault. The judge found the juvenile not delinquent and sealed the case record under Ohio Revised Code (R.C.) 2151.356(B)(1)(d). After the juvenile was later killed, the Cincinnati Enquirer requested the trial transcript, which the judge denied, citing the statute.The Cincinnati Enquirer challenged the constitutionality of R.C. 2151.356, arguing that the Ohio Constitution's open courts provision prohibits sealing court records without an individualized determination balancing the interests of the juvenile and the public. The juvenile court judge argued that the open courts provision does not apply to juvenile delinquency proceedings, relying on precedent from the Ohio Supreme Court.The Supreme Court of Ohio reviewed the case and held that the open courts provision of the Ohio Constitution applies to juvenile delinquency proceedings. The court determined that R.C. 2151.356 is unconstitutional because it mandates the sealing of records without an individualized balancing of interests. The court granted a writ of mandamus ordering the juvenile court judge to provide access to the trial transcript and a writ of prohibition preventing the enforcement of the sealing order. View "State ex rel. Cincinnati Enquirer v. Bloom" on Justia Law

In 2017, a minor admitted to two counts of assault with intent to commit rape and was initially placed in a Level B program. Due to multiple probation violations, the juvenile court later committed him to the Division of Juvenile Justice (DJJ) in 2019. After being discharged from DJJ in April 2023, the juvenile court imposed a probation condition requiring the minor to register as a sex offender under Penal Code section 290.008. The minor appealed, arguing that this requirement violated his equal protection rights because it treated him differently from minors who committed similar offenses after the juvenile justice realignment, which closed DJJ and transferred responsibilities to county facilities.The Superior Court of Sacramento County upheld the probation condition, rejecting the minor's equal protection argument. The court found that the sex offender registration requirement did not involve a loss of liberty and thus did not implicate a fundamental right, applying the rational basis standard of review. The court reasoned that the Legislature could have determined that minors in county facilities have a lower risk of recidivism due to more effective treatment, justifying the differential treatment.The California Court of Appeal, Third Appellate District, reviewed the case de novo and affirmed the lower court's decision. The court held that the rational basis standard applied because the sex offender registration requirement did not involve a fundamental right or suspect classification. The court found that a rational basis existed for the differential treatment, as the Legislature could have reasonably concluded that minors already in DJJ custody posed a higher risk of recidivism and required continued registration to protect public safety. Thus, the court found no equal protection violation and affirmed the dispositional order. View "People v. I.B." on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

A mother, K.G., gave birth to twins in September 2020. Due to concerns about her mental health and ability to care for the children, Muskingum County Adult and Child Protective Services (the agency) took emergency temporary custody of the children. The children were placed with their maternal aunt. The juvenile court adjudicated the children as dependent and continued the agency's temporary custody. K.G. was required to undergo a psychological evaluation, which revealed several mental health conditions that could impair her parenting abilities.The juvenile court later transferred temporary legal custody to the maternal aunt, with the agency maintaining protective supervision. The agency then moved for the maternal aunt to be granted legal custody and for the agency's supervision to be terminated. At the hearing, the agency presented a psychological report by Dr. Wolfgang, which K.G. objected to, arguing she should be able to cross-examine the psychologist. The juvenile court admitted the report and granted legal custody to the maternal aunt.The Fifth District Court of Appeals reversed the juvenile court's decision, holding that K.G.'s due process rights were violated because she was not able to cross-examine Dr. Wolfgang. The agency appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the appellate court's decision, holding that the juvenile court was permitted to consider the psychologist’s report under the statutory scheme governing legal-custody proceedings. The court found that K.G. was not denied an opportunity to cross-examine Dr. Wolfgang and that her due process rights were not violated. The case was remanded to the appellate court for consideration of K.G.'s remaining assignment of error. View "In re R.G.M." on Justia Law

In this case, the United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of absolute and qualified immunity to two County of San Bernardino social workers, Gloria Vazquez and Mirta Johnson. The plaintiffs, Sydney Rieman and her minor child K.B., alleged that the social workers violated their Fourth and Fourteenth Amendment rights by failing to provide them notice of a juvenile detention hearing and by providing false information to the Juvenile Court about why Ms. Rieman was not noticed for the hearing.The court held that the social workers were not entitled to absolute immunity for their actions and omissions, such as providing false information to the Juvenile Court and failing to give notice of the detention hearing. These actions were not similar to discretionary decisions about whether to prosecute. Absolute immunity did not apply to the plaintiffs' claim that the defendants failed to give them notice of the detention hearing as such notice was mandatory.The court also held that the defendants were not entitled to qualified immunity from suit for failing to provide notice of the hearing. Ms. Rieman had a due process right to such notice and that right was clearly established. The court stated that it was clear at the time that parents could not be summarily deprived of the care and custody of their children without notice and a hearing, except when the children were in imminent danger.Finally, the court held that the defendants were not entitled to qualified immunity for their misrepresentation to the Juvenile Court about why Ms. Rieman was not noticed for the hearing. The court concluded that a reasonable social worker in the defendants' shoes would have understood, based on prior decisional law, that providing incomplete and false information to the Juvenile Court about Ms. Rieman’s whereabouts to convince the court that the social workers had satisfied the due process notice requirement constituted judicial deception. View "RIEMAN V. VASQUEZ" on Justia Law

In the midst of a group contacted by officers for smoking cannabis on the street, 16-year-old T.F.-G. witnessed first one and then another of his companions be restrained, searched, and made to sit on the curb as the officers worked their way through the group. T.F.-G. ran. Chased, tackled, and punched, he was arrested for resisting or delaying a peace officer (Pen. Code 148(a)). In a search incident to that arrest, the police found a loaded handgun in his pocket, which T.F.-G. was not licensed to carry.The court of appeal affirmed his convictions. The totality of the circumstances, establishing the existence of probable cause for his arrest for resisting or delaying a peace officer—the asserted basis for the eventual search that revealed his possession of a loaded handgun in public–indicated that a reasonable person in T.F.-G.’s position would have understood he was not free to leave. The court also rejected a Second Amendment facial challenge to the prohibition on the unlicensed public carrying of loaded firearms. Although California’s “good cause” licensing requirement is undisputedly unconstitutional under the Supreme Court’s 2022 “Bruen” decision, the unconstitutionality of a discrete licensing requirement does not render section 25850 facially unconstitutional. View "In re T.F.-G." on Justia Law