Justia Juvenile Law Opinion Summaries

A 17-year-old defendant was charged with ten serious offenses, including murder and assault, after a violent confrontation at the home of his rivals. The incident stemmed from a feud with a classmate and escalated when the defendant, accompanied by his family, armed himself and attacked the victims’ home. The attack resulted in the death of one individual and severe injuries to others. The defendant, an enrolled member of the Cherokee Nation, was charged under federal law for crimes committed within the Cherokee Nation Indian Reservation.The United States District Court for the Eastern District of Oklahoma first reviewed the case. The government moved to transfer the defendant from juvenile to adult criminal proceedings under the Juvenile Justice and Delinquency Prevention Act. After an evidentiary hearing, the magistrate judge recommended granting the transfer, and the district court adopted this recommendation after conducting a de novo review. The district court weighed the statutory factors, including the defendant’s age, social background, psychological maturity, prior delinquency record, past treatment efforts, and the availability of rehabilitative programs, and found that most factors favored transfer to adult status.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court did not abuse its discretion in weighing the statutory transfer factors and found no clear error in its factual findings. The court also rejected the defendant’s Eighth Amendment argument that transfer was unconstitutional due to the potential punishments, holding that the challenge was unripe under circuit precedent. The Tenth Circuit affirmed the district court’s order transferring the defendant to adult criminal proceedings. View "United States v. J.D.V., Jr." on Justia Law

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law

The case concerns Kenneth Robinson, who was convicted of malice murder and other offenses related to the shooting death of Devontae Jones and the aggravated assault of Charmisa Witherspoon. The evidence showed that Robinson, age fourteen at the time, was involved with the 9 Trey Bloods gang. After a gang member, Jesus Cintron, disappeared, the gang’s leader plotted to kill Witherspoon and her son, fearing Witherspoon would cooperate with law enforcement. Robinson and other gang members went to Witherspoon’s house, where Robinson participated in the assault. Witherspoon escaped, but her son was killed. Robinson was tried alongside several co-defendants.The Superior Court of Fulton County granted Robinson a directed verdict on several counts and dead docketed one count, later nol prossed. The jury found Robinson guilty on the remaining counts except one. He was sentenced to life plus forty-five consecutive years. Robinson filed a motion for new trial, which was denied. His initial appeal was dismissed due to a pending count, but after that count was nol prossed, he filed an amended notice of appeal.The Supreme Court of Georgia reviewed the case. Robinson argued that his trial counsel was ineffective for failing to communicate a plea offer, that his sentencing procedure violated constitutional and statutory rights, that the trial court misunderstood its sentencing discretion, and that certain counts should have merged for sentencing. The court held that trial counsel did communicate the plea offer, so there was no deficient performance. The court also found no constitutional or statutory violation in the sentencing procedure, noting that neither Robinson nor his counsel objected or requested to be heard. Claims regarding the trial court’s sentencing discretion and merger of counts were found to be waived or without merit. The Supreme Court of Georgia affirmed Robinson’s convictions. View "ROBINSON v. THE STATE" on Justia Law

In November 2016, D.J., then 15 years old, was involved in a marijuana transaction that resulted in the shooting death of J.S. The State charged D.J. with felony murder, aggravated robbery, and possession of marijuana. D.J. agreed to plead no contest in exchange for the case being designated as an extended jurisdiction juvenile prosecution (EJJP) rather than being tried as an adult. The court sentenced D.J. to a juvenile correctional facility until he was 22 years, 6 months old, with an adult sentence of life without parole for 25 years for the felony murder count, among other penalties, stayed as long as D.J. complied with his juvenile sentence.In October 2021, D.J. was released on conditional release but was later found in a vehicle with firearms and marijuana, and in July 2022, he was caught driving without a license and possessing marijuana. The State moved to revoke D.J.'s juvenile sentence, and the district court found that D.J. had violated the conditions of his juvenile sentence by possessing firearms and marijuana and eluding law enforcement.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the revocation of D.J.'s juvenile sentence. The court also held that under K.S.A. 38-2364, the district court was required to revoke the juvenile sentence and impose the adult sentence upon finding a violation of the juvenile sentence. The court rejected D.J.'s arguments that the district court had discretion to continue the stay of the adult sentence and that the district court could modify the adult sentence under K.S.A. 22-3716.The court also dismissed D.J.'s constitutional proportionality claims, stating that case-specific challenges could not be raised for the first time on appeal and that D.J. failed to comply with Supreme Court Rule 6.02(a)(5) for his categorical challenge. Finally, the court declined to review D.J.'s ineffective assistance of counsel claim due to the lack of a Van Cleave hearing and insufficient factual development in the record. View "In re D.J. " on Justia Law

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