Justia Juvenile Law Opinion Summaries

Defendant Eduardo Lopez, Jr. committed murder at age 17. Following his conviction, defendant received a statutorily-mandated sentence of life imprisonment without the possibility of parole. In 2012, the United States Supreme Court issued Miller v. Alabama, 567 U.S. 460 (2012), ruling that “the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders.” Accordingly, in 2017, the trial court held a two-day resentencing hearing at which it heard testimony from the arresting police officer, several members of the murder victim’s family, an addiction psychiatrist, a forensic psychologist, several members of the defendant’s family, and the defendant. Following the hearing, taking into consideration the record before it, “the nature and circumstances of the underlying crime, the characteristics of the defendant, and the traditional sentencing factors,” the court imposed a sentence of 45 years to life. Defendant appealed that sentence, arguing 45-year-to-life constituted a de facto equivalent of of lifetime imprisonment in violation of the Eighth Amendment to the United States Constitution. The New Hampshire Supreme Court held the trial court did not err in determining that the 45-year-to-life sentence it imposed, under which defendant had an opportunity to be considered for parole when he reached 62 years of age, was not a de facto life sentence under the Eighth Amendment to the Federal Constitution. Accordingly, the sentence was affirmed. View "New Hampshire v. Lopez, Jr." on Justia Law

In November 2017, M.S. was charged with third degree assault of a King County Metro bus driver. M.S. approached the driver’s side window of a King County bus while it was parked. When the bus driver leaned out the driver’s side window to speak to M.S., M.S. squirted urine from a plastic bottle at the bus driver. M.S. pleaded guilty to a reduced charge of fourth degree assault and requested a deferred disposition of the criminal assault charge. The court also asked M.S. if he understood that the court could impose a manifest injustice sentence outside the standard range if it found aggravating factors. The court did not mention at the hearing or in the plea agreement any existing aggravating factors it could rely on if it did impose a manifest injustice sentence. The court granted M.S.’s request for a deferred disposition and in it required M.S. to comply with a number of conditions of community supervision. The trial court ultimately sentenced M.S. to a manifest injustice disposition based on facts and aggravating factors that M.S. had no notice of at the time of his plea. The Court of Appeals affirmed M.S.’s sentence and rejected M.S.’s argument that any right to notice of the factual basis of a manifest injustice disposition existed prior to pleading guilty. The issue this case presented for the Washington Supreme Court's review centered on whether a juvenile, before entering a guilty plea in a criminal proceeding, had a statutory or constitutional due process right to notice of the factual basis of and the intent to seek a manifest injustice disposition. The Supreme Court reversed the Court of Appeals and held that a juvenile has a right to notice of the factual basis necessary to support a manifest injustice sentence before deciding to plead guilty. View "Washington v. M.S." on Justia Law

In 2017, D.L., a 14-year-old boy, was charged with three counts of first degree rape and one count of attempted first degree rape of his 5-year-old half brother. At the time, D.L. had no prior criminal history. D.L. successfully negotiated a plea deal with the prosecutor, reducing the charges to a single count of first degree attempted child molestation. D.L. stipulated in his plea agreement that the trial court could use the probable cause statement to determine the facts that supported his conviction. But when the court imposed the manifest injustice disposition, it relied on three facts that were not in the probable cause affidavit: (1) that D.L.’s victim had a cognitive disability; (2) that D.L. refused accountability; and (3) that D.L. would not cooperate with treatment. This case asked the Washington Supreme Court whether due process required that the State give a juvenile notice of these specific facts before pleading guilty if they will be used to justify a manifest injustice disposition. "Ultimately, due process requires that juveniles be treated in a manner that is fundamentally fair. ... Without adequate notice, juveniles and their attorneys cannot predict which facts might be unearthed and weaponized to extend the juvenile’s sentence after the plea. This lack of notice causes unfair surprise to young defendants and serves only to undermine juveniles’ and their families’ trust in our juvenile justice system. Our adult defendants in Washington are not treated so unfairly and neither should we so treat our juveniles." As a result, the manifest injustice disposition was improperly imposed. As D.L. already served his sentence and this case was technically moot; the Court resolved this legal issue without modifying D.L.’s sentence. View "Washington v. D.L." on Justia Law

Applicant Steven Thomas was 16 when he committed capital murder. When he was 19, the juvenile court waived its exclusive jurisdiction and transferred Applicant’s case to district court, where Applicant pleaded guilty to a lesser charge of murder. Decades passed. Applicant did not appeal his transfer or his case or file a writ of habeas corpus. Then, the Texas Court of Criminal Appeals decided Moon v. Texas, 451 S.W.3d 28 (Tex. Crim. App. 2014), which held that if an order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, then the order is invalid, and the district court never acquires jurisdiction. Based upon Moon, Applicant argued that because the order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, it was invalid, and thus the district court never acquired jurisdiction. The Court of Criminal Appeals found that the type of findings Moon required were neither grounded in the text of the transfer statute, nor in Kent v. United States, 383 U.S. 541 (1966), the Supreme Court precedent that it purportedly relied upon in Moon. "Requiring them may be good policy, but the lack of case-specific findings has nothing to do with jurisdiction, fundamental constitutional rights, or even the transfer statute itself. The juvenile court’s transfer order in this case may have lacked factually-supported, case-specific findings, but that did not make that order invalid or deprive the district court of jurisdiction." Consequently, the Court determined Applicant was not entitled to habeas corpus relief. View "Ex parte Steven Thomas" on Justia Law

Fifteen-year-old Lucas Orozco was charged with robbery and burglary, both felonies, for allegedly robbing a convenience store. After a magistrate court determined there was probable cause to charge Orozco with the felonies, it waived juvenile jurisdiction and bound him over to district court as an adult pursuant to Idaho Code section 20-509. Orozco objected to this automatic waiver, filing a motion with the district court challenging the constitutionality of section 20-509. The district court denied the motion, relying on precedent from the Idaho Court of Appeals, which previously upheld the constitutionality of section 20-509. Orozco appealed, arguing that the automatic waiver denied him procedural due process protections afforded to him by the U.S. Constitution. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Orozco" on Justia Law

Jermontae Moss was convicted of felony murder, possession of a firearm during the commission of a crime, and theft by receiving stolen property in connection with the 2011 shooting death of Jose Marin. At the time of the crime, Moss was 17 years old and sentenced to life without the possibility of parole. On appeal, he contended he received ineffective assistance of trial counsel, and that the court erred in imposing that sentence. Finding no merit to either contention, the Georgia Supreme Court affirmed Moss' conviction and sentence. View "Moss v. Georgia" on Justia Law

Petitioners Dwayne Bartholomew and Kurtis Monschke were each convicted of aggravated first degree murder and sentenced to life in prison without possibility of parole - a mandatory, nondiscretionary sentence under Washington’s aggravated murder statute. Bartholomew was 20 years old; Monschke was 19. Many years after their convictions, each filed a personal restraint petition (PRP) asking the Washington Supreme Court to consider whether article I, section 14 of the state constitution or the Eighth Amendment to the United States Constitution permitted a mandatory life without parole (LWOP) sentence for youthful defendants like themselves. "[W]hen it comes to mandatory LWOP sentences, [Miller v. United States, 567 U.S. 460 (2012)]'s constitutional guarantee of an individualized sentence - one that considers the mitigating qualities of youth - must apply to defendants at least as old as these defendants were at the time of their crimes." Accordingly, the Supreme Court granted both PRPs and ordered that Bartholomew and Monschke each receive a new sentencing hearing. View "In re Pers. Restraint of Monschke" on Justia Law

When Indiana officials determine that a child is suffering abuse or neglect, they initiate the Child in Need of Services (CHIN) process. Lawyers are automatically appointed for parents but not for children in the CHINS process. The plaintiffs, children in the CHINS process, claimed that they are entitled to counsel. The Seventh Circuit affirmed the dismissal of the suit, citing “Younger” abstention. While declining to decide that Younger would mandate abstention in all CHINS cases, the court reasoned that principles of comity entitle states to make their own decisions. Because children are not automatically entitled to lawyers, as opposed to the sort of adult assistance that Indiana routinely provides, it would be inappropriate for a federal court to resolve the appointment-of-counsel question in any of the 10 plaintiffs’ state proceedings. A state judge may decide to appoint counsel or may explain why counsel is unnecessary. View "Nicole K. v. Stigdon" on Justia Law

Defendant Justin Link committed aggravated murder as a juvenile in 2001. He was sentenced to a term of life imprisonment, which, as defined by statute at the relevant time, required him to serve “a minimum of 30 years without possibility of parole.” After serving that minimum term of confinement, defendant could petition to convert his sentence to life imprisonment with the possibility of parole. In this case, defendant argued the statute under which he was sentenced violated the Eighth Amendment to the United States Constitution. The Court of Appeals agreed. The Oregon Supreme Court allowed the state’s petition for review, and reversed, finding defendant did not establish that the statutory scheme applicable here denied him a meaningful opportunity for release. "Therefore, the sentence that defendant received is not the functional equivalent of life without parole. It follows that defendant has failed to establish that Miller’s individualized-sentencing requirement applies to a sentence of 'life imprisonment' under ORS 163.105(1)(c) (2001)." The circuit court's order was affirmed. View "Oregon v. Link" on Justia Law

The Supreme Court upheld Senate Bill 1391 as a permissible amendment to Proposition 57 and reversed the judgment in the case, holding that the Legislature acted within its authority.Proposition 57, which was passed in the November 2016 general election, allowed prosecutors to move to transfer some minors as young as fourteen years old from juvenile court to adult criminal court. Senate Bill 1391, enacted in 2018, amended Proposition 57 to prohibit minors under the age of sixteen from being transferred to adult criminal court. The court of appeal held that Senate Bill 1391 was invalid because it was inconsistent with Proposition 57. The Supreme Court reversed, holding that the amendment was fully consistent with and furthered Proposition 57's purposes of promoting rehabilitation of youthful offenders and reducing the prison population, and therefore, Senate Bill 1391 was a constitutional amendment to Proposition 57. View "O.G. v. Superior Court" on Justia Law