Justia Juvenile Law Opinion Summaries

In February 2017, five-year-old N.H. reported to her grandfather that E.S. “has me put his missy in my mouth.” N.H.’s grandfather asked her to repeat herself, with which she complied, but otherwise he did not inquire further. According to N.H.’s grandfather, “missy” was the term N.H. used at the time to describe a person's genitalia. He repeated N.H.’s disclosure to N.H.’s mother who then reported the allegations to law enforcement. The Louisiana Supreme Court granted the writ in this matter primarily to address the constitutionality of mandatory lifetime sex offender registration under R.S. 15:5421 as applied to a juvenile. E.S. was ultimately adjudicated delinquent for the first degree rape of a child under the age of thirteen years old. Finding that there was insufficient evidence to determine E.S. was fourteen years old at the time of the offense, and therefore mandatory disposition pursuant to Ch. C. art. 897.13 and R.S. 15:542 was inapplicable to the case at hand, the Supreme Court affirmed the adjudication of first degree rape, reversed the court of appeal’s determination that there was sufficient evidence to establish E.S.’s age, vacated the disposition of the district court and remanded for further proceedings. View "Louisiana in the Interest of E.S." on Justia Law

At 11:20 p.m., Gosuwin, carrying a pursed and holding an iPhone, saw two “young black men” wearing hoodies coming around the corner. One pushed her to the ground. The assailants pulled her bag and phone away, then continued on Market Street toward the Embarcadero. Gosuwin went to a nearby building, where a security guard called the police. Gosuwin did not see any weapons on her assailants. An officer used the “Find My iPhone app.” Gosuwin’s phone was “pinging” on the Embarcadero. Officer found Gosuwin’s purse there. At 11:29 p.m., officers received a dispatch call and went to the area to look for the “robbery suspects.” They noticed Jeremiah and J.A., both juveniles. One was wearing a hoodie. During the ensuing stop, an officer instructed Jeremiah to face a wall with his legs spread and his arms above his head. He did so. There was nothing about Jeremiah’s appearance, behavior, or actions to indicate that Jeremiah was armed and dangerous. A pat-down search revealed two phones in Jeremiah’s pocket. One phone’s background picture and password matched Gosuwin’s phone. The juvenile court denied a motion to suppress and ordered Jeremiah transferred to Alameda County where a previous wardship petition alleging second-degree robbery was pending. The court of appeal reversed the jurisdiction and disposition orders. The officer who conducted the pat-down did not present specific and articulable facts to support a reasonable suspicion that Jeremiah was armed and dangerous. The court declined to recognize a rule that would validate essentially any “pat-search” of a suspected robber who is lawfully detained following a report of a fresh robbery. View "In re Jeremiah S." on Justia Law

A juvenile from a small village could not afford to travel to the site of his juvenile delinquency proceeding. His attorney with the Public Defender Agency (the Agency) filed a motion asking the superior court to require the Division of Juvenile Justice (DJJ) to pay the travel expenses for both the juvenile and one of his parents. The superior court denied the motion and required the Agency to pay the expenses. The court of appeals upheld the superior court’s decision, reasoning that the Agency’s authorizing statute could plausibly be interpreted to cover client travel expenses and that this reading was supported by administrative guidance in the form of two Attorney General opinions and a regulation governing reimbursements by the Office of Public Advocacy (OPA). The Alaska Supreme Court granted the Agency’s petition for hearing, asking the Agency and DJJ to address two questions: (1) whether the Agency has a statutory obligation to pay its clients’ travel expenses; and (2) whether DJJ has a statutory obligation to pay those expenses. The Supreme Court concluded neither entity’s authorizing statutes required the payment and therefore reversed the court of appeals. The Court did not address the question of how these necessary expenses were to be funded; the Court surmised that was an issue for the executive and legislative branches. View "Alaska Public Defender Agency v. Superior Court" on Justia Law

The Supreme Court affirmed the judgment of the habeas court rendering judgment against Petitioner, a juvenile offender, on his claim that the evolution of Connecticut's "standards of decency" regarding acceptable punishments for children who engage in criminal conduct has rendered the transfer of his case to the regular criminal docket and resultant sentencing unconstitutional, holding that Petitioner was not entitled to relief on his claims.Petitioner, who was fourteen years old when he committed felony murder, argued that his sentence as an adult after his case was automatically transferred to the regular criminal docket violated the state prohibition against cruel and unusual punishment. The habeas court denied relief. The Supreme Court affirmed, holding (1) transferring the case of a fourteen year old defendant to the regular criminal docket comports with evolving standards of decency and, therefore, does not violate the Connecticut constitution; and (2) Petitioner's forty year sentence does not violate the constitutional prohibition against cruel and unusual punishment after the provisions of P.A. 15-84 made Petitioner eligible for parole after serving sixty percent of his original sentence. View "Griffin v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the decision of the Appellate Court affirming the trial court's dismissal of Defendant's motion to correct an illegal sentence, holding that because Defendant is now eligible for parole under No. 15-84 of the 2015 Public Acts (P.A. 15-84) the Connecticut constitution did not require a resentencing of his unconstitutional sentence.Defendant, a juvenile offender, was convicted of murder and sentenced to thirty-five years' imprisonment. At the time of sentence, Defendant was indelible for parole. Thereafter, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. To comply with federal constitutional requirements the legislature passed P.A. 15-84. As a result, Defendant will be parole eligible after serving twenty-one years. Thereafter, Defendant filed a motion to correct an illegal sentence, asserting a violation of Miller v. Alabama, 467 U.S. 460 (2012). The trial court dismissed the motion for lack of jurisdiction. The Appellate Court ultimately affirmed on the ground decided in State v. Delgado, 151 A.3d 345 (Conn. 2016). The Supreme Court affirmed, holding that, consistent with Delgado and the federal constitution, Defendant's parole eligibility afforded by P.A. 15-84, 1 was an adequate remedy for the Miller violation. View "State v. Williams-Bey" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the legislature may and has remedied the constitutional violation in this case with parole eligibility.Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law

Defendant-appellant O.C., appealed an order denying her petition to seal her juvenile court records and related records in the custody of law enforcement and other agencies. She claimed the court was required to seal her records under Welfare & Institutions Code section 786 because she satisfactorily completed her juvenile court probation in April 2011. The Court of Appeal affirmed denial. O.C. was not qualified to seal her records under section 781 because: (1) she was convicted of six felonies in May 2018, after the juvenile court’s jurisdiction over her terminated in April 2011; and (2) in denying O.C.’s sealing petition, the court found that O.C. had not obtained rehabilitation since April 2011, based on the facts underlying her six felony convictions. View "In re O.C." on Justia Law

Michael Damion Jude Medrano was convicted by jury on one count of first-degree murder, two counts of second degree robbery, and one count of assault with force likely to produce great bodily harm. Medrano was 19 years old when he committed the offenses. He was sentenced to 25 years to life, plus seven. Medrano was sentenced in December 2017, one and one-half years after the California Supreme Court decided California v. Franklin, 63 Cal.4th 261 (2016), which held that when a juvenile offender receives an indeterminate life sentence, the offender must be “given adequate opportunity at sentencing to make a record of mitigating evidence tied to his youth.” The Court remanded the case to the trial court to determine whether the juvenile offender had been given an adequate opportunity to make such a record. Medrano asked the Court of Appeal to give him the same relief that was granted in Franklin. But because Medrano was sentenced one and one-half years after Franklin, and because nothing in the record indicated Medrano lacked an adequate opportunity at sentencing to make a record of mitigating youth-related evidence, the Court found no basis to order the same relief that the Supreme Court granted in Franklin. It noted, however, that the Supreme Court recently held that a juvenile offender whose conviction and sentence were final could file a motion under Penal Code section 1203.01 for the purpose of making a record of mitigating youth-related evidence. View "California v. Medrano" on Justia Law

In a moot case of substantial and continuing public interest, a juvenile offender challenges whether her need for treatment was an appropriate basis for imposing a manifest justice disposition. B.O.J. pled guilty to two counts of third degree theft for shoplifting from a grocery store. These offenses subjected her to a "local sanctions" standard sentencing range. In exchange for a plea, the prosecution promised to recommend 6 months of community supervision, 8 hours of community service, credit for time served, release at her sentencing disposition, and no contact with the victims. One month later, the State contended B.O.J. violated the conditions of her release by running away from placement. The State thereafter recommended a manifest justice disposition with confinement in a Juvenile Rehabilitation Administration facility. The trial court stated its findings that both B.O.J.'s need for treatment and the standard sentencing range as too lenient supported the manifest injustice disposition. The Washington Supreme Court determined the trial court's findings were not an appropriate basis for imposing a manifest injustice disposition. The Court reversed the Court of Appeals' holding that B.O.J.'s need for treatment supported the trial court's finding that a standard range disposition would effectuate a manifest injustice. View "Washington v. B.O.J." on Justia Law

This case centered on the validity of a a changed law that raised the minimum age at which a juvenile could be tried in criminal court. The new law amended a provision of the “Public Safety and Rehabilitation Act” (Proposition 57), which the voters approved in 2016 with the express goals of reducing prison spending, emphasizing rehabilitation for youth offenders, and limiting prosecutorial authority over the decision to try a minor as an adult. To advance these goals, Proposition 57 eliminated prosecutors’ ability to directly file charges against minors ages 14 to 17 in criminal court, requiring them instead to seek the juvenile court’s permission by way of a transfer hearing. In 2018, the Legislature enacted the law at issue here, Senate Bill Number 1391 (2017-2018 Reg. Sess., "SB 1391"), which eliminated prosecutors’ ability to seek transfer hearings for 14 and 15 year olds, effectively raising the minimum age a child can be tried as an adult from 14 to 16. The change affected B.M.’s prosecution for murder. SB 1391 became effective after the Riverside County District Attorney had filed a wardship petition against the then 15-year-old, and had moved to transfer her to criminal court. While the transfer motion was pending, the juvenile court (respondent Riverside County Superior Court) ruled the new law was invalid because it did not further what it identified as Proposition 57’s goal of giving judges the authority to transfer 14 to 17 year olds to criminal court. B.M. sought mandamus relief, arguing the trial court misinterpreted Proposition 57's purpose in declaring SB 1391 invalid. The Court of Appeal agreed, finding SB 1391 furthered each of Proposition 57’s express purposes, including the one concerned with limiting prosecutorial discretion. The Court therefore granted B.M.’s petition for a writ of mandate and directed the juvenile court to vacate its order declaring SB 1391 invalid. View "B.M. v. Superior Court" on Justia Law