Justia Juvenile Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's sentence of three consecutive terms of life imprisonment, with the possibility of parole after forty-five years, in connection with his conviction of three counts of murder in the first degree, holding that the sentence was within constitutional bounds.Defendant was a juvenile homicide offender and sought resentencing when he was well into adulthood. After the Supreme Judicial Court decided Commonwealth v. Costa, 472 Mass. 139 (2015), the Commonwealth conceded that Defendant was entitled to a resentencing hearing. After a hearing, the sentencing judge reinstated Defendant's sentence. Defendant then filed an application with the Supreme Court pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal from the resentencing judge's ruling, as well as a motion for direct entry of the appeal. The single justice directed entry of the appeal on the question of whether a juvenile homicide offender may be required to serve forty-five years in prison before his first opportunity to seek release based on rehabilitation. The Supreme Judicial Court held that Defendant's sentence did not constitute cruel or unusual punishment in violation of article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. LaPlante" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and the order denying his motion for a new trial, holding that Defendant's sentence was constitutional and that no prejudicial error occurred in the proceedings below.Defendant, who was seventeen years of age at the time of the murder, was sentenced to a mandatory term of life imprisonment with eligibility for parole after fifteen years. The Supreme Judicial Court disagreed, holding (1) a mandatory life sentence with parole eligibility after fifteen years for a juvenile homicide offender convicted of murder in the second degree is constitutional; (2) the judge did not err in denying Defendant's motion to continue his sentence so that he could present evidence related to his juvenile status; (3) the judge did not err in denying Defendant's request to instruct the jury on accident; (4) Defendant's counsel was not ineffective for not requesting other jury instructions; and (5) the judge did not err in denying Defendant's motion to suppress the warrantless "pinging" of Defendant's cellular telephone because no evidence came from the search. View "Commonwealth v. Lugo" on Justia Law

Petitioner filed suit challenging the Director's repeated denial of parole to petitioner. The district court granted the Director's motion to dismiss, holding that juvenile-specific Eighth Amendment protections do not apply to petitioner because he was sentenced to life with parole, and that the Parole Board procedures satisfied procedural due process requirements under the Fourteenth Amendment.Reading petitioner's 28 U.S.C. 2254 petition as a 42 U.S.C. 1983 complaint, the Fourth Circuit declined to extend the Supreme Court's Eighth Amendment jurisprudence to juvenile parole proceedings and find that it is cruel and unusual punishment for a parole board to deny juvenile offenders parole without specifically considering age-related mitigating characteristics as a separate factor in the decisionmaking process. In regard to the Fourteenth Amendment claim, the court held that, although there was no constitutional or inherent right to parole proceedings, Virginia law gives rise to an expectation of parole proceedings that has created a liberty interest in parole consideration. The court held that, nevertheless, to satisfy the due process requirements triggered by this liberty interest, a parole board need only provide an offender an opportunity to be heard and a statement of reasons indicating why parole has been denied. In this case, petitioner's parole proceedings satisfied those requirements. View "Bowling v. Director, Virginia Department of Corrections" on Justia Law

The phrase "officials or employees of any governmental agency with responsibility for the administration of juvenile justice," as it is used in 34 U.S.C. 12601(a), does not include the judges of a county youth court. The Fifth Circuit affirmed the district court's judgment in an action under section 12601, alleging that Lauderdale County and its two Youth Court judges operated a "school-to-prison pipeline" and, through their administration of the juvenile justice process, were engaged in patterns or practices that denied juveniles their constitutional rights under the Fourth, Fifth, and Fourteenth Amendments. The court held that the district court did not err in dismissing the lawsuit against the judges on the basis that they are outside the scope of Section 12601, and because the government has affirmatively waived any other argument for continuing the lawsuit against the County. View "United States v. Lauderdale County" on Justia Law

Iowa closed the Iowa Girls State Training School. Palmer, Director of the Iowa Department of Human Services, subsequently contracted to use the Wisconsin Girls State Training School (Copper Lake). Plaintiffs claim that, since its 2011 opening, Cooper Lake “has had a very high turnover rate of employees,” leading to “over-worked and untrained staff” and has received criticism from Wisconsin judges regarding its “sordid” and “inhumane” treatment of juveniles. Iowa juvenile courts ordered Plaintiffs to be placed at Copper Lake in 2015. Both were 16 years old. Plaintiffs claim that Copper Lake subjected them to prolonged “isolation,” and that they received little or no educational instruction. Both attempted suicide. Plaintiffs also claim they were subjected to excessive force and that staff sprayed them with mace on multiple occasions. Plaintiffs sued under 42 U.S.C. 1983 for cruel and unusual punishment, excessive force, and deprivation of due process. The Seventh Circuit reversed the dismissal of their claims. The district court acted prematurely in deciding Palmer’s entitlement to qualified immunity at the motion to dismiss stage. At the time plaintiffs were allegedly in Palmer’s custody, isolation of pre-trial juvenile detainees not “reasonably related to a legitimate governmental objective”could rise to the level of a constitutional violation. On the record, it is impossible to determine whether such a constitutional violation occurred in plaintiffs’ cases. View "Reed v. Palmer" on Justia Law

The Supreme Judicial Court reversed the superior court judge’s denial of Defendant’s motion for resentencing, holding that Defendant, a juvenile convicted of armed home invasion, was sentenced to a mandatory minimum term exceeding that applicable to a juvenile convicted of murder without a hearing under Miller v. Alabama, 467 U.S. 460, 477-478 (2012), in violation of the requirements announced in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), and refined in Commonwealth v. Perez, 480 Mass. __ (2018) (Perez II), also decided today.Defendant was adjudicated a youthful offender on indictments charging armed home invasion and various related offenses and was sentenced to a mandatory minimum prison term of twenty years to twenty years and one day on the armed him invasion charge. Defendant later filed a motion for relief from unlawful restraint, which the juvenile court judge denied. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded to the juvenile court for resentencing, holding that Defendant’s sentence violated the proportionality requirement inherent in article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. Lutskov" on Justia Law

The Supreme Court reversed the determination of the trial court finding that R.R., a juvenile, violated his probation and adjudicating him a delinquent for auto theft and false informing, holding that the trial court violated R.R.’s right to be present at the fact-finding hearing by holding hearing in R.R.’s absence.On appeal, R.R. argued that juveniles have a due process right to be present at fact-finding hearings on a delinquency charge and that the trial court violated this right by holding the hearing in his absence. The Supreme Court assumed without deciding that juveniles are entitled to be present at fact-finding hearings and held (1) a juvenile can waive his right to be present at a fact-finding hearing but must do so according to the juvenile waiver-of-rights statute; (2) there was no waiver of R.R.’s right to be present, and therefore, the trial court violated that right by holding the fact-finding hearing in R.R.’s absence; and (3) the absurdity doctrine did not apply to this case. View "R.R. v. State" on Justia Law

The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements.The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

The Ninth Circuit affirmed the district court's denial of a petition for habeas relief challenging a sentencing enhancement for a prior nonjury juvenile conviction and for a gang-related crime. Petitioner argued that the evidence supporting the gang enhancement was constitutionally insufficient under Jackson v. Virginia, 443 U.S. 307 (1979), and that the enhancement for his nonjury juvenile conviction violated Apprendi v. New Jersey, 530 U.S. 466 (2000).The panel held that it was objectively unreasonable to conclude that the evidence was sufficient for a reasonable jury to find the robbery was committed "in association with" a gang; but it was not objectively unreasonable to conclude that the evidence was sufficient for a reasonable jury to find the robbery was committed "for the benefit of" a gang. The panel also held that the juvenile conviction claim was procedurally barred, and the sentencing enhancements based on nonjury juvenile convictions did not violate any clearly established federal law as determined by the United States Supreme Court. View "Johnson v. Montgomery" on Justia Law

A jury convicted fourteen-year-old Lawrence Montoya for the New Year’s Day murder of a teacher from his school. After serving over thirteen years in prison, Montoya brought post-conviction claims for ineffective assistance of counsel and actual innocence. He sued several detectives involved in the investigation and trial, claiming they were responsible for his wrongful conviction pursuant to 42 U.S.C. 1983. Specifically, Montoya claimed the Detectives instigated a malicious prosecution against him, coerced his confession in violation of the Fifth Amendment, and subjected him to false arrest. The Detectives appealed when the district court held qualified immunity and absolute testimonial immunity did not shield the Detectives from liability and denied their motion to dismiss. After review, the Tenth Circuit held qualified immunity indeed shielded the Detectives from liability for Montoya’s malicious prosecution claim; both qualified immunity and absolute testimonial immunity barred Montoya’s Fifth Amendment claim. As for Montoya’s false arrest claim, the Court determined it lacked jurisdiction to consider whether or not qualified immunity applied. View "Montoya v. Vigil" on Justia Law