Justia Juvenile Law Opinion Summaries

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

D.D., a juvenile, was adjudicated delinquent for committing second-degree rape at the age of fourteen and was committed to the custody of the Office of Juvenile Justice until his twenty-first birthday. Upon release, he was required to register as a sex offender. D.D. challenged the constitutionality of this registration requirement, arguing it violated the Sixth and Eighth Amendments of the U.S. Constitution. The juvenile court denied his motion.D.D. appealed to the Court of Appeal, First Circuit, which affirmed both the adjudication and the denial of his constitutional claims. D.D. then sought review from the Supreme Court of Louisiana, which granted his writ application.The Supreme Court of Louisiana held that the sex offender registration requirement for juveniles does not constitute cruel and unusual punishment under the Eighth Amendment, as it is a civil regulatory measure intended to protect public safety rather than a punitive action. The court also found that the registration requirement does not implicate the Sixth Amendment's right to a jury trial, as juvenile proceedings are fundamentally different from adult criminal trials and do not require a jury trial for due process. The court affirmed D.D.'s adjudication and the denial of his motion to declare the registration requirement unconstitutional. View "In re D.D." on Justia Law

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

A juvenile court in a dependency proceeding granted a restraining order requested by a mother, K.B., against her 17-year-old dependent child, D.B. The Santa Clara County Department of Family and Children’s Services had received multiple referrals over the years concerning D.B.'s well-being due to alleged abuse and neglect by the mother. D.B. had a history of physical altercations with her mother and was placed in protective custody after her mother refused to allow her back home following an arrest for assault.The Santa Clara County Superior Court assumed jurisdiction over D.B. and declared her a dependent child. The court adopted a case plan that included supervised visitation with the mother. However, D.B. struggled in her placement and exhibited behavioral issues. The mother later requested termination of reunification services, which the court granted with D.B.'s agreement.Subsequently, the mother filed for a restraining order against D.B., citing threats and harassment. The court issued a temporary restraining order and later a one-year restraining order after a hearing. The court found that section 213.5 of the Welfare and Institutions Code authorized it to issue restraining orders against a dependent child and determined that it was in D.B.'s best interest to do so.The California Court of Appeal, Sixth Appellate District, reviewed the case and affirmed the juvenile court's decision. The appellate court held that section 213.5, subdivision (a), grants the juvenile dependency court authority to issue restraining orders against a dependent child, provided the child's best interest is considered. The court found substantial evidence supporting the restraining order and concluded that it did not violate D.B.'s constitutional rights, as reunification services had already been terminated with D.B.'s consent. View "In re D.B." on Justia Law

A child was temporarily removed from her parents' care shortly after birth and placed in the custody of the Department of Children and Families (DCF) due to concerns about domestic violence. DCF sought to vaccinate her according to an age-based immunization schedule, but her parents, practicing Rastafarians, objected on religious grounds. A Juvenile Court judge allowed DCF to facilitate vaccinations for the child. The parents sought to stop future vaccinations, arguing that vaccinating their child over their religious objections violated their constitutional rights.The Juvenile Court judge found that the parents' religious beliefs were outweighed by the child's best interests and allowed DCF to vaccinate the child. The parents petitioned the Appeals Court for interlocutory relief, which was denied. The parents then appealed to the Appeals Court panel, and the child sought direct appellate review in the Supreme Judicial Court, which was granted.The Supreme Judicial Court of Massachusetts held that the order allowing the child to be vaccinated violated the parents' constitutional rights. The court concluded that the parents' sincerely held religious beliefs were substantially burdened by DCF's vaccination efforts. The court applied the State constitutional protections afforded to parents exercising their free exercise rights and determined that DCF failed to demonstrate that exempting the child from vaccinations would substantially hinder the fulfillment of DCF's interests in promoting child health. The court noted the Commonwealth's allowance of religious exemptions from vaccination requirements for parents who have not lost custody and DCF's inconsistent exercise of its authority to order vaccinations for children in its care. The order allowing the joint motion by DCF and the child to facilitate the vaccination of the child was reversed. View "Care and Protection of Eve" on Justia Law

McKinley Kelly, at sixteen, was convicted of murdering three young adults. The trial court vacated one conviction and sentenced him to 110 years in prison. Kelly's appeals and petitions for post-conviction relief were unsuccessful. The Court of Appeals allowed him to file a successive petition for post-conviction relief, focusing on new scientific understandings of adolescent brain development, arguing for a resentencing or a more lenient sentence.The Lake Superior Court denied Kelly's petition, and the Court of Appeals affirmed. Kelly then appealed to the Indiana Supreme Court, which granted transfer to address procedural and substantive issues related to juvenile sentencing. The Indiana Supreme Court affirmed the post-conviction court's decision, concluding that the post-conviction court appropriately allowed Kelly to amend his successive petition without requiring appellate screening.The Indiana Supreme Court held that the state and federal constitutional provisions cited by Kelly did not mandate a more lenient sentence. The court found that Kelly's sentence was not inappropriate given the nature of his offenses and his character. The court emphasized that the legislature had recently amended the sentence modification statute to allow juvenile offenders to have their sentences reexamined after twenty years, providing an opportunity for review based on rehabilitative progress.The court concluded that Kelly's new evidence on adolescent brain development was cumulative and unlikely to produce a different result. The court also rejected Kelly's claims under the Indiana Constitution, finding that his sentence did not violate provisions related to cruel and unusual punishment, proportionality, reformation, unnecessary rigor, or equal protection. Similarly, the court found no violation of the Eighth or Fourteenth Amendments of the U.S. Constitution. Finally, the court declined to revise Kelly's sentence under Appellate Rule 7(B), finding it appropriate in light of the nature of his offenses and his character. View "Kelly v. State of Indiana" on Justia Law

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