Justia Juvenile Law Opinion Summaries

Articles Posted in Constitutional Law
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In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

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The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

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The case involves a juvenile, J.L.J., who was charged with first-degree felony murder and several other offenses after he opened fire on a car, killing a 12-year-old boy. J.L.J. was certified for adult prosecution and testified that he was acting in self-defense. The jury rejected his self-defense claim and convicted him on all charges.The case was previously heard in the Leavenworth District Court where J.L.J. was convicted. On appeal, J.L.J. raised several claims of error, including prosecutorial errors and the argument that the State unconstitutionally pitted his right to prepare for his defense against his right to testify at trial.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court found that while the prosecutor erred by asking potential jurors if they would do their "job" and convict J.L.J., this error was harmless and did not affect the jury's verdict. The court also disagreed with J.L.J.'s argument that the prosecutor misstated the law on self-defense during closing argument. Furthermore, the court found that the State's impeachment of J.L.J. did not violate the unconstitutional-conditions doctrine. Lastly, the court declined to invoke an exception to the general preservation rule to address J.L.J.'s argument that the adult certification process violates his constitutional rights. View "State v. J.L.J." on Justia Law

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The Supreme Court of Nevada addressed whether the provision under NRS 62C.200(1)(b) violates the separation of powers doctrine. This provision requires the district attorney's written approval before a juvenile court may dismiss a delinquency petition and refer a juvenile to informal supervision. The appellant, a juvenile referred to as I.S., was adjudicated a delinquent and placed on formal probation. I.S. appealed, arguing that the provision infringed upon the court's sentencing discretion, essentially granting an unconstitutional prosecutorial veto.The court concluded that I.S.'s appeal was not moot, despite the completion of his juvenile supervision, due to the presumption of collateral consequences of such an adjudication until the juvenile reaches age 18 and/or their juvenile record is sealed.On the main issue, the court held that the requirement under NRS 62C.200(1)(b) does not contravene the separation of powers doctrine. The court reasoned that this provision does not involve a sentencing decision. Rather, the court perceived it as akin to a charging decision, which is within the executive realm. The court further noted that, unlike adult courts, the juvenile court's authority is not derived from the constitution but is limited to the authority expressly prescribed to it by statute. Therefore, the court affirmed the district court's order, holding that the requirement for the district attorney's written approval before a juvenile court can dismiss a petition does not violate the separation of powers doctrine. View "In re I.S." on Justia Law

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This case before the Indiana Supreme Court concerns a juvenile, A.W., who was adjudicated for possession of a machine gun and dangerous possession of a firearm. The court was asked to determine if these adjudications violated the principle of double jeopardy under Indiana law. A.W. asserted that he did not know the firearm he possessed had been modified to function as a machine gun.The court found that A.W.'s exclusive possession of the modified gun, along with his abrupt flight from police, supported the conclusion that he knowingly or intentionally possessed a machine gun. This satisfied the first part of the court's inquiry.On the issue of double jeopardy, the court noted that while the Indiana Constitution could apply in juvenile proceedings, it avoided deciding that issue. Instead, it focused on whether possession of a dangerous firearm is a lesser-included offense of possession of a machine gun under the test set out in the case Wadle v. State. The court found that it was, meaning A.W.'s adjudications for both offenses violated his rights under the principle of double jeopardy. Therefore, the court affirmed the finding that A.W. knowingly possessed a machine gun but reversed the adjudication that he committed dangerous possession of a firearm. View "A. W. v. State of Indiana" on Justia Law

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In the case before the Supreme Court of the State of Kansas, the appellant, the State of Kansas, challenged a trial court's decision to suppress the confession of a minor identified as G.O. The trial court had determined that the confession was not voluntary, and therefore inadmissible. The Court of Appeals reversed the trial court's decision, prompting G.O. to appeal to the Supreme Court.The Supreme Court of Kansas considered whether G.O.'s waiver of his Fifth Amendment rights and his confession were voluntary. Under the Fifth Amendment, an individual has the right to remain silent and not incriminate themselves. This right can be waived if the individual voluntarily, knowingly, and intelligently chooses to speak. The court also examined whether G.O.’s Fourteenth Amendment rights were violated, which protect against involuntary confessions being used as evidence.The court found that while G.O. had been read his Miranda rights, the detective conducting the interview had made misleading statements that suggested G.O. was not in trouble and would not be arrested. The detective further suggested that the purpose of the interview was to help G.O.'s stepsister, which the court found was deceptive.The court also took into account G.O.’s age, his mental health issues, his lack of experience with law enforcement, and his educational struggles. The court concluded that these factors, in combination with the detective’s misleading statements, induced G.O. to confess involuntarily.Therefore, the court held that the trial court was correct in suppressing G.O.'s confession. It reversed the Court of Appeals' decision and affirmed the trial court's judgment. View "State v. G.O." on Justia Law

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The Supreme Court of Pennsylvania considered whether a violation of a juvenile defendant's Fifth Amendment right is subject to appellate review for harmless error. The case involved Nazeer Taylor, who was charged with several serious felony offenses as a juvenile. The juvenile court transferred Taylor's case to adult criminal court, considering Taylor's refusal to admit guilt for his alleged offenses as a factor in its decision. The Supreme Court of Pennsylvania previously held that such consideration violated Taylor's Fifth Amendment right. In this appeal, the Supreme Court concluded that the violation constituted a structural error, not subject to a harmless error review. Given Taylor's current age of 27, neither the juvenile nor the adult criminal court had the statutory authority to conduct a new certification hearing. Consequently, the Supreme Court affirmed the order of the Superior Court reversing Taylor's conviction and discharging him. View "Commonwealth v. Taylor" on Justia Law

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In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

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In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

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C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law