Justia Juvenile Law Opinion Summaries

The Second Circuit affirmed the district court's order granting a preliminary injunction in favor of Hartford and enjoining defendants, who are administrators and clerks at the Connecticut Superior Court, from enforcing a Connecticut statute that mandates automatic sealing of all judicial records and closure to the public of all court proceedings in criminal prosecutions of juvenile defendants transferred to the regular criminal docket.The court held that Public Act Number 19-187 is unconstitutional. The court concluded that the Courant has a qualified First Amendment right of access to criminal prosecutions of juveniles in regular criminal court. The court agreed with the district court that, for cases in criminal court, even those involving juvenile defendants, the "place and process" have historically been open to the public. Furthermore, public access plays a significant positive role in the functioning of the particular process in question. The court also concluded that the Act infringes on that right because it is not narrowly tailored to serve a compelling state interest. Finally, the court concluded that the Courant has shown that all four requirements for a preliminary injunction have been met. View "Hartford Courant Co., LLC v. Carroll" on Justia Law

A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication.The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings. View "Doe v. Shenandoah Valley Juvenile Center Commission" on Justia Law

Defendants Harquan Johnson and KeAndre Windfield were each convicted of one count of murder and one count of attempted murder, and assault with a semi-automatic firearm, along with gun discharge and gang enhancement allegations as to the murder and attempted murder counts. The charges arose from the shooting of two members of their own gang, the Ramona Blocc Hustlas, resulting in the death of one of them. Both defendants were sentenced to prison for 90 years to life. They appealed raising various claims. In the original opinion, filed August 2014, the Court of Appeal affirmed both defendants' convictions, but reversed Johnson’s sentence pursuant to California v. Gutierrez, 58 Cal.4th 1354 (2014), because, as a juvenile at the time of the crime, his sentence of 90 years to life was the functional equivalent of a term of life without possibility of parole and we directed other modifications of the sentence and abstracts of judgment. In November 2014, the California Supreme Court denied both defendants’ petitions for review, but, on its own motion, issued a grant-and-hold of review as to defendant Johnson, for consideration pending review in In re Alatriste, S214652, In re Bonilla, S214960, and California v. Franklin, S217699. In May 2016, the Supreme Court issued its decision in Franklin (63 Cal.4th 261 (2016)), and retransferred his case to the Court of Appeal with directions reconsider Johnson’s sentence. The appellate court issued a second opinion in September 2016, affirming those portions of the original opinion pertaining to issues not subject to the grant and hold, and reconsidered Johnson's sentence. Defendants again successfully petitioned for review; the Supreme Court retransferred the cases to the Court of Appeal with directions to reconsider the case in light of California v Canizales, 7 Cal.5th 591 (2019), and California v. Perez, 3 Cal.App.5th 612 (2016). Judgment was modified per direction, and defendants again appealed. In April 2020, the Supreme Court again transferred this matter to the appellate court to reconsider in light of Senate Bill 620 (Stats. 2017, ch. 682). After reconsideration, the Court of Appeal affirmed both defendants' convictions. As to Windfield, a hearing was warranted for both defendant and the State to make an accurate record of defendant’s characteristics and circumstances at the time of the offense, and to amend his abstract of judgment fix a date error. As to Johnson, the case was remanded for the limited purpose of a fitness hearing: if not fit, Johnson's convictions were to be reinstated; if the juvenile court found it would not have transferred Johnson to be tried as an adult, it should treat his convictions as juvenile adjudications and impose an appropriate "disposition" within its discretion. In addition, the court could exercise its discretion whether to strike or dismiss any of the firearm enhancements within the meaning of Senate Bill No. 620. View "California v. Windfield" on Justia Law

E.P., a minor in a juvenile delinquency proceeding, challenged a July 2020, decision by respondent Yolo County Superior Court, which denied his motion to physically appear in juvenile court in the presence of the judge at court hearings. Petitioner claimed the court’s decision, as well as certain temporary local rules (Super. Ct. Yolo County, Temporary COVID-19 Local Rules) issued by the court in response to the COVID-19 pandemic, conflicted with Welfare and Institutions Code section 679 and the emergency rules related to COVID-19 adopted by the Judicial Council and contained in appendix I of the California Rules of Court. The Court of Appeal concluded that, consistent with section 679 and the case law interpreting it, the emergency rules required a court obtain a minor’s consent before conducting a hearing in a juvenile delinquency proceeding remotely. Accordingly, the respondent superior court erred in denying petitioner’s motion to physically appear in court at his juvenile hearings. To the extent the court’s temporary local rules required all hearings in juvenile delinquency proceedings be conducted remotely absent a finding of good cause, the rules were in conflict with both section 679 and the emergency rules. View "E.P. v. Superior Court" on Justia Law

The Supreme Court held that Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal.A jury found Defendant guilty of aggravated murder and other offenses stemming from a fatal shooting when Defendant was seventeen years old. The trial court sentenced Defendant to life imprisonment with parole eligibility after thirty years for the aggravated murder offense. On appeal, Defendant argued that his sentence violated the Eighth and Fourteenth Amendments. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal; and (2) consistent with this Court's decision in State v. Long, 8 N.E.3d 890 (Ohio 2014), a trial court must separately consider the youth of a juvenile offender as a mitigating factor before imposing a life sentence under Ohio Rev. Code 2929.03 even if that sentence includes eligibility for parole. View "State v. Patrick" on Justia Law

Several boys broke into two homes, one of which was owned by a man old enough to be considered an “at-risk” victim. When that man returned home, he happened upon one of the boys holding the "spoils of an ill-conceived, juvenile burglary." The others, including B.D., remained outside, oblivious to the elderly man’s arrival. All the boys quickly fled. By this opinion, the Colorado Supreme Court addressed the scope of complicitor liability for a fact that aggravates the punishment for theft; namely, an at-risk victim’s presence. Based on the plain language of the controlling statutes, the Supreme Court concluded that a complicitor need not be aware that an at-risk victim was present because it was a strict liability sentence enhancer and not an element of the offense. Accordingly, the Court reversed the judgment of the court of appeals and remanded the case for the district court to reinstate the adjudication and sentence. View "Colorado in the Interest of B.D." on Justia Law

Defendant-appellant D.H. (minor) had a history of defiant and criminal behavior, resulting in him being placed on formal probation in two juvenile delinquency matters. Throughout his probationary period, D.H. violated the law and the terms and conditions of his probation. While still on probation, the juvenile court dismissed the Welfare and Institutions Code section 602 petitions and terminated D.H.'s probation as unsuccessfully completed based on a joint request from the San Bernardino County Children and Family Services (CFS) and the probation department to transfer jurisdiction to the dependency court under section 300. D.H. requested the juvenile court seal his section 602 juvenile delinquency records, and the juvenile court denied his request. On appeal, D.H. argued the juvenile court was required to seal his records under Welfare and Institutions Code section 786 (e). Alternatively, he contended the juvenile court abused its discretion in denying his motion to seal his records under section 786(a). Finding no reversible error, the Court of Appeal affirmed. View "In re D.H." on Justia Law

After receiving a citizen’s tip that Black males in a Mercedes were “acting shady,” four San Diego Police Department (SDPD) officers drove to the scene in two marked vehicles, activating emergency lights in one. Parking behind the Mercedes, the officers positioned themselves beside each of its four doors and asked the three teenagers inside for their names and identification. A records check later indicated that the driver was on probation subject to a Fourth Amendment waiver. The officers searched the vehicle and recovered a loaded firearm and sneakers linking the minors to a recent robbery. The minors moved to suppress the evidence found in the car, claiming their initial detention was not supported by reasonable suspicion. Finding the encounter was consensual rather than a detention, the juvenile court denied the motions. Two of the minors pleaded guilty to a subset of the charges originally filed. In a consolidated appeal, two of the minors, Edgerrin J. and Jamar D. challenged the denial of their motions to suppress, arguing the juvenile court erred in finding the encounter consensual, and claimed the citizen’s tip did not establish reasonable suspicion to detain them. To this, the Court of Appeal agreed on both points. However, the Court found conflicting evidence as to whether officers knew other facts that might furnish reasonable suspicion for the stop, or justify the detention and search pursuant to Edgerrin’s active Fourth Amendment waiver. Because the rationale for its ruling made it unnecessary for the juvenile court to address these other issues, judgment was reversed and remanded for a new hearing to permit it to assess witness credibility and reach factual findings in the first instance. View "In re Edgerrin J." on Justia Law

In January 2019, 15-year old Heather Juliano was a passenger in a sport-utility vehicle driven by Shakyla Soto in the vicinity of the Capital Green development in Dover, Delaware. Corporal Robert Barrett of the Dover Police Department was patrolling the area, accompanied by Probation Officer Rick Porter, as part of the Department’s Safe Streets program. Corporal Barrett spotted Soto’s SUV exiting Capital Green and noticed that the occupant of the front passenger seat was not wearing a seat belt. Corporal Barrett decided to pull the vehicle over. Almost immediately after Barrett initiated contact with the driver, he heard Porter say “1015 which means take . . . everybody into custody.” Three other Dover Police Department officers arrived on the scene in very short order. All four occupants of the SUV were removed from the vehicle and handcuffed in response to Porter’s order. The SUV was then searched, but no contraband was found. One officer searched backseat passenger Keenan Teat and found a knotted bag containing crack cocaine in one of his pants pockets. Another officer searched passenger Zion Saunders and found both marijuana and heroin in his jacket pockets. But when Officer Johnson searched Juliano, he found no contraband, but $245.00 in cash. Juliano was later taken to the police station, and strip-searched. Officers found marijuana and a bag of cocaine in her pants. Juliano was charged with Tier 1 possession of narcotics plus an aggravating factor (aggravated possession of cocaine), drug dealing, and possession of marijuana. The Delaware Supreme Court determined there was nothing unreasonable in a motor vehicle stop based on an officer's reasonable suspicion the operator or occupant of the vehicle committed a violation of the law - here, traffic laws. "Equally so, we are not prepared to say that, once a vehicle is lawfully stopped, the police must ignore evidence of other criminal activity when that evidence itself is lawfully uncovered." Rejecting Juliano's appellate claims with regard to the initial traffic stop and the suppression od evidence, the Supreme Court felt compelled to address "certain conspicuous irregularities" in the trial court's order denying Juliano's motion to suppress: (1) the trial court did not articulate a basis for finding a reasonable suspicion sufficient to justify the extension of the traffic stop to investigate the vehicle's occupants; and (2) the court's order did not explain the basis upon which the custodial arrest and threatened strip search were justified. The matter was remanded to the trial court for more complete statements of the factual and legal bases with respect to Juliano's search and subsequent arrest. View "Juliano v. Delaware" on Justia Law

The Supreme Judicial Court affirmed the order of the juvenile court judge denying a juvenile's motion for relief from sex offender registration, holding that the record below was inadequate for the Court to decide the constitutional issue presented by the juvenile in this case.After the juvenile court judge denied the juvenile's motion to be relieved from his obligation to register as a sex offender the juvenile filed a petition seeking relief under Mass. Gen. Laws ch. 211, 3, arguing that requiring juveniles to register violates due process and constitutes cruel and unusual punishment based on advances in the understanding of the adolescent brain. The Supreme Judicial Court denied relief, holding (1) based on the record, the judge's determination that the juvenile should not be relieved of the obligation to register as a sex offender did not lie outside the bounds of reasonable alternatives; and (2) because of the absence of expert testimony and the failure to properly introduce the scientific studies cited in the judge's written findings, the Court did not have the necessary record to reach the constitutional issue. View "Ernest E. v. Commonwealth" on Justia Law