Justia Juvenile Law Opinion Summaries

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

A minor, J.H.-M., was adjudicated guilty of second-degree rape by forcible compulsion. The juvenile court imposed a Special Sex Offender Disposition Alternative, including 30-40 weeks of confinement, suspended for a 24-month supervision period. Conditions of supervision included maintaining employment or school enrollment, compliance with treatment requirements, and registration. Although the sentencing judge verbally declined to impose a condition prohibiting sexually explicit material, the written order included this prohibition.J.H.-M. appealed to the Court of Appeals, arguing that the condition prohibiting sexually explicit material was unconstitutionally vague and overbroad. The State initially moved to concede error based on the judge's verbal statement, but Division One of the Court of Appeals denied the motion and directed briefing on the merits. The Court of Appeals affirmed the condition, concluding it was not unconstitutionally vague or overbroad, distinguishing it from a similar condition in a previous case, State v. Padilla.The Supreme Court of the State of Washington reviewed the case. The court held that the condition prohibiting sexually explicit material was not unconstitutionally vague. The court reasoned that the term "sexually explicit conduct" was sufficiently defined by prior case law and the referenced statute, former RCW 9.68A.011(4), which provided specific examples of prohibited acts. The court concluded that the condition provided adequate notice of proscribed conduct and ascertainable standards to prevent arbitrary enforcement. The Supreme Court affirmed the imposition of the condition and the decision of the Court of Appeals. View "State v. J.H.-M." on Justia Law

The defendant, a seventeen-year-old, was convicted of the abduction and murder of eighty-nine-year-old Elleze Kennedy. Along with his co-defendants, the defendant followed Ms. Kennedy home, assaulted her, and placed her in the trunk of her car. They later set the car on fire, resulting in Ms. Kennedy's death from carbon monoxide poisoning. The defendant was sentenced to life in prison without parole.The Superior Court of Onslow County initially sentenced the defendant to life without parole. The Court of Appeals upheld this sentence, finding no error. The defendant then filed a motion for appropriate relief, arguing that his sentence was unconstitutional under Miller v. Alabama, which requires consideration of a juvenile's age and potential for rehabilitation before imposing a life without parole sentence. The Superior Court held a resentencing hearing and reaffirmed the life without parole sentence, considering the Miller factors.The Supreme Court of North Carolina reviewed the case. The court held that the defendant's J.E.B. claim, alleging gender bias in jury selection, was procedurally barred because it was not raised at trial or on direct appeal. The court also affirmed the lower court's decision to sentence the defendant to life without parole, finding that the sentencing court properly considered the Miller factors, including the defendant's age, immaturity, ability to appreciate risks, prior record, mental health, and potential for rehabilitation. The court concluded that the sentencing court did not abuse its discretion in weighing these factors and that the sentence did not violate the Eighth Amendment. The decision of the Court of Appeals was affirmed. View "State v. Sims" on Justia Law

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and 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 the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation 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. 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 the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" 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 this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law

In 1984, Roger Scott Helm, Jr., then 14 years old, murdered his adoptive parents and stepsister. He was arrested and charged with multiple counts, including first-degree murder. Helm pleaded guilty to one count of first-degree murder, two counts of second-degree murder, and one count of armed robbery. The trial court sentenced him to life imprisonment for the first-degree murder with eligibility for parole after 25 years, followed by consecutive sentences totaling an additional 42 years for the other counts.Helm's case was transferred from juvenile to adult court, and he was sentenced after a detailed hearing where the court considered mitigating factors such as his age and drug influence, as well as aggravating factors like his lack of remorse and dangerousness. The Arizona Supreme Court upheld the consecutive sentences on direct appeal.Helm later filed for post-conviction relief, arguing that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Arizona trial court and the Arizona Court of Appeals rejected his claim, stating that Miller does not apply to consecutive sentences for multiple crimes. The Arizona Supreme Court denied review.The United States Court of Appeals for the Ninth Circuit reviewed Helm's habeas corpus petition. The court assumed, for argument's sake, that Helm's sentence was the functional equivalent of life without parole. However, it concluded that Helm's sentence complied with Miller because the trial judge had discretion and considered Helm's youth before imposing the sentence. The Ninth Circuit affirmed the district court's denial of Helm's habeas corpus petition, holding that Helm's sentence did not violate the Eighth Amendment as interpreted in Miller and clarified in Jones v. Mississippi. View "Helm v. Thornell" on Justia Law