Justia Juvenile Law Opinion Summaries
Articles Posted in Civil Rights
In re D.R.
The Supreme Court affirmed the judgment of the court of appeals determining that Ohio Rev. Code 2152.84(A)(2)(b) was fundamentally unfair as applied to D.R., the juvenile in this case, and thus violated his right to procedural due process, holding that the court of appeals did not err.D.R. was adjudicated delinquent for sexually assaulting his friend when he was sixteen years old. The juvenile court suspended D.R.'s commitment and placed him on probation with conditions. The court classified D.R. as a Tier I offender and notified him that he had a duty to register as a sex offender. At the end of D.R.'s disposition, the magistrate terminated D.R.'s probation but continued his Tier I classification on the grounds that it lacked the statutory authority the terminate the classification. The court of appeals reversed. The Supreme Court affirmed, holding that the statute was fundamentally unfair as applied to D.R. and violated due process. View "In re D.R." on Justia Law
In re D.N.
The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the juvenile court finding true that Minor had committed one count of violating Cal. Penal Code 288.5 and order probation, thus rejecting Minor's claims that a community service provision of the disposition violated separation of powers principles and infringed his due process rights, holding that there was no error.In affirming, the appellate court acknowledged that a juvenile court may not delegate to a probation officer the authority to determine that a minor is in violation of probation but held that, in this case, the juvenile court's order permitting the probation officer to offer Minor the option of community service for an alleged violation did not permit the probation department to decide if and when a violation of probation had occurred. The Supreme Court affirmed, holding that the juvenile court order authorizing the probation officer to offer Minor on probation the option of performing community service, in an amount chosen by the probation officer up to a maximum set by the court, in the event Minor was alleged to have violated a term of probation, did not violate due process or separation of powers principles. View "In re D.N." on Justia Law
State v. Nicholas
The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law
Keefe v. State
The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law
In re C.A.R.A.
The Supreme Court vacated the judgment of the circuit court finding that Juvenile committed acts that would constituted first-degree statutory sodomy if committed by an adult, holding that the circuit court erroneously declared and applied the law in admitting two-way video testimony, in violation of Juvenile's right to confrontation.Prior to his adjudication hearing, Juvenile filed an objection to a virtual adjudication and request to appear in person, arguing that he had a constitutional and statutory right to face-to-face confrontation of witnesses against him. The objection was overruled, and the court held the hearing in a "hybrid" format that utilized videoconferencing technology due to the COVID-19 pandemic. After the hearing, the circuit court sustained the allegation of first-degree statutory sodomy beyond a reasonable doubt. The Supreme Court vacated the judgment, holding that the circuit court's general statements concerning COVID-19 did not satisfy the requisite standard for admitting two-way video testimony, in violation of Juvenile's confrontation rights. View "In re C.A.R.A." on Justia Law
People v. Jones
Jones was a juvenile in 2000 when he pled guilty to first-degree murder and was sentenced to 50 years in prison pursuant to a fully negotiated plea agreement. After unsuccessfully petitioning for postconviction relief, Jones sought leave to file a successive postconviction petition alleging his sentence violated the eighth amendment protections in the Supreme Court’s “Miller v. Alabama” decision.The appellate court affirmed the denial of his motion, finding that Jones’ claims did not invoke the protections provided to juveniles in Miller. The Illinois Supreme Court affirmed. Miller’s additional protections for juvenile offenders apply only when a trial court lacks or refuses to use discretion in sentencing a juvenile offender to life, or to a de facto life, sentence. The mandatory sentencing scheme that applied in Illinois at the time he was sentenced was never applied to Jones. By entering a plea agreement, a defendant forecloses any claim of error. A voluntary guilty plea waives all non-jurisdictional errors or irregularities, including constitutional ones. Jones has not claimed that the state engaged in any misrepresentation or committed any misconduct. View "People v. Jones" on Justia Law
Y.C. v. Superior Court
A wardship petition charged Y.C., then 17 years old, with assault with a firearm, carrying a loaded firearm, and possession of a firearm by a minor. Y.C. allegedly shot a suspected rival gang member in the leg. Arrested, Y.C. was taken to the Juvenile Assessment Center, where he met with a probation officer and invoked his Miranda rights. Y.C. agreed to participate in a mental health assessment conducted by a family therapist, pursuant to an established protocol of the Juvenile Services Division of the San Mateo County Probation Department. The therapist provided a summary of her interview to the probation department, which included the summary in a report provided to the juvenile court at Y.C.’s detention hearings.The court of appeal dismissed Y.C.’s writ petition as moot to the extent that it sought relief relating to his detention During the pendency of the proceeding, Y.C. entered a change of plea and was released from detention. The court otherwise denied the petition, rejecting arguments that the disclosure of the assessment interview to the probation department and juvenile court, and its use at his detention hearings, violated his constitutional right against self-incrimination and his right to counsel, as well as HIPAA and California’s Confidentiality of Medical Information Act. View "Y.C. v. Superior Court" on Justia Law
People v. Sands
In 2001, Sands was 24 years old when he committed special circumstance murder (Penal Code 187, 190.2(a)(10)) and was sentenced to a prison term of life without the possibility of parole. The trial court denied his motion, seeking to develop a record of mitigating circumstances for an eventual youth offender parole hearing under “Franklin.”The court of appeal affirmed, rejecting his Equal Protection argument. The statute provides an opportunity for release (via youth offender parole hearings) to most persons convicted of crimes committed before the age of 26 in their 15th, 20th, or 25th year of incarceration, depending on the sentence imposed for their “[c]ontrolling offense,” sections 3051(a)(2)(B), (b)(1)-(4). The statute excludes offenders who were sentenced to life without the possibility of parole for crimes they committed at age 18-25. The Legislature had a rational basis to distinguish between offenders with the same sentence (life without parole) based on their age. For juvenile offenders, such a sentence may violate the Eighth Amendment but the same sentence does not violate the Eighth Amendment when imposed on an adult, even an adult under the age of 26. The Legislature could rationally decide to remedy unconstitutional sentences but go no further. View "People v. Sands" on Justia Law
Brown v. Precythe
In an action arising from a constitutional challenge to Missouri's remedial parole review process for individuals sentenced to mandatory life without the possibility of parole for homicide offenses committed as juveniles, a class of Missouri inmates who were sentenced to mandatory life without parole for such juvenile homicide offenses filed suit claiming that Missouri's parole review policies and practices violate their rights to be free from cruel and unusual punishment and their rights to due process of law under the U.S. Constitution and the Missouri Constitution. The district court granted summary judgment in favor of plaintiffs.The Eighth Circuit agreed with the district court that Missouri's policies and practices, when implemented and considered in combination, worked to deprive plaintiffs of their Eighth Amendment right to a meaningful opportunity to obtain release based upon demonstrated maturity and rehabilitation. The court explained that, because the parole review process in place under Senate Bill 590 failed to adequately ensure that juveniles whose crimes reflect only transient immaturity—and who have since matured—will not be forced to serve a disproportionate sentence, it violated the Eighth Amendment.The court affirmed the order of the district court determining that the parole review process of SB 590 violated plaintiffs' Eighth Amendment rights, and affirmed the order determining that Missouri cannot use a risk assessment tool in its revised parole proceedings unless it has been developed to address the unique circumstances of the JLWOP Class. The court vacated the order regarding appointment of counsel and remanded for further proceedings. Finally, the court denied plaintiffs' motion to strike. View "Brown v. Precythe" on Justia Law
State v. N.R.
The Supreme Court affirmed the judgment of the court of appeals finding that lifetime registration requirements under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), were not punishment as applied N.R. and therefore did not trigger any constitutional provisions identified by N.R., holding that there was no error.N.R. pled guilty to rape and was adjudicated a juvenile offender. The gestate judge ordered N.R. to register as a sex offender for five years under KORA. Just before N.R.'s registration period was about to expire, the legislature amended KORA. As a result, N.R. was required to register for life. Later, the State charged N.R. for failing to register. N.R. filed a motion to dismiss, arguing that KORA's mandatory lifetime registration requirements for juvenile sex offenders violates the federal and state constitutional provisions against cruel and unusual punishment and the federal constitutional provision against ex post facto punishment. The district court found Defendant guilty. The Supreme Court affirmed, holding that KORA's mandatory lifetime registration requirements as applied to N.R. are not punishment and therefore do not violate the federal Ex Post Facto Clause or the prohibition against cruel and unusual punishment under the Kansas and United States Constitutions. View "State v. N.R." on Justia Law