Justia Juvenile Law Opinion Summaries

A.M. (juvenile) appealed an unpublished Court of Appeals decision affirming her conviction for possession of a controlled substance. She argued: (1) it was manifest constitutional error for the trial court to admit a detention center inventory form where she signed a sworn statement indicating that a backpack, which was discovered to contain methamphetamine, was her property because it violated her right against self-incrimination; and (2) the affirmative defense of unwitting possession was an unconstitutional burden-shifting scheme that violated her due process rights. After review, the Washington Supreme Court held the admission of the inventory form was manifest constitutional error because it violated her right against self-incrimination and warranted reversal because it was not harmless error. Because the Court found reversible constitutional error, it declined to consider A.M.'s due process argument. The case was remanded back to the trial court for further proceedings. View "Washington v. A.M." on Justia Law

Indiana statutes provided a fast and confidential judicial bypass procedure that is supposed to allow a small fraction of pregnant, unemancipated minors seeking abortions to obtain them without the consent of or notice to their parents, guardians, or custodians, Ind. Code 16-34-2-4(b). In 2017, Act 404 added a parental notification requirement: Parents must be given prior notice of the planned abortion unless the judge also finds such notice is not in the minor’s “best interests” unlike the judicial bypass of parental consent, which may be based on either maturity or best interests. The district court issued a preliminary injunction against enforcement of the new notice requirements, finding it likely to “create an undue burden for a sufficiently large fraction of mature, abortion-seeking minors in Indiana.” The Seventh Circuit affirmed. Indiana’s notice law creates a substantial risk of a practical veto over a mature yet unemancipated minor’s right to an abortion. This practical veto appears likely to impose an undue burden for the unemancipated minors who seek to obtain an abortion without parental involvement via the judicial bypass. Indiana has made no effort to support with evidence its claimed justifications or to undermine with evidence Planned Parenthood’s showing about the likely effects of the law. View "Planned Parenthood of Indiana and Kentucky, Inc. v. Adams" on Justia Law

Vas Coleman was arrested at his home in Huntsville, Alabama on charges related to the 2015 death of Jose Greer in Fulton County, Georgia. Although Coleman was sixteen years old at the time of his arrest, the Fulton County Superior Court had exclusive jurisdiction over his case pursuant to OCGA 15-11-560 (b) (1) because he was accused of murder. After his arrest, Coleman was held at the Fulton County Youth Detention Center until he was granted a bond on March 24, 2016, and subsequently released. On April 8, 2016, Coleman was indicted by a Fulton County grand jury, along with four co-defendants, for felony murder and burglary in relation to Greer’s death. Almost two years later, on March 20, 2018, Coleman and his co-defendants were re-indicted on the same charges. After the State nolle prossed the April 2016 indictment, Coleman filed a motion to transfer his case to juvenile court, arguing that, because the March 2018 indictment was returned outside the 180-day time limit set by OCGA 17-7-50.1, the Superior Court no longer had jurisdiction. Relying on the Court of Appeals’ decisions in Edwards v. Georgia, 748 SE2d 501 (2013) and Georgia v. Armendariz, 729 SE2d 538 (2012), the trial court granted Coleman’s motion to transfer. The State appealed, arguing that the trial court granted the motion in error. “Reading the statute in its most natural and reasonable way,” the Georgia Supreme Court concluded the 180-day time limitation in OCGA 17-7-50.1 did not apply to a juvenile who was released and remained on bond prior to the running of 180 days. The Court overruled Edwards, and further concluded the trial court erred in transferring Coleman’s case to the juvenile court. View "Georgia v. Coleman" on Justia Law

The State of New Hampshire filed a petition for original jurisdiction seeking review of a circuit court order denying a request by the Office of the Attorney General (AGO) to release records underlying its investigation into an incident involving minors. According to the AGO, in 2017, there was an incident involving several minors in Claremont, New Hampshire. The AGO, the United States Attorney’s Office, the Federal Bureau of Investigation, and the Claremont Police Department jointly investigated the incident. Subsequently, the Sullivan County Attorney filed delinquency petitions in the circuit court against one of the juveniles. The AGO asserted that the evidence obtained during the investigation was not confidential under RSA 169-B:35 but, even if it were, “significant policy considerations” allowed disclosure as long as the juvenile’s identity was protected. Following a hearing, the trial court rejected the AGO’s argument that RSA chapter 169-B did not apply to the AGO’s investigatory records. The court stated that “RSA 169-B:35 provides that all case records relative to delinquencies are confidential. Publication of information concerning a juvenile case is strictly prohibited with few legislatively enacted exceptions. None of those exceptions apply in this case.” The New Hampshire Supreme Court affirmed the circuit court’s ruling that the records were confidential under RSA 169-B:35 (Supp. 2018). View "Petition of the State of New Hampshire" on Justia Law

At issue in this case was a Family Court order adjudging appellant Joseph Baker, Jr., a minor child, delinquent for having committed an act of Rape in the Second Degree. Initially, Baker was charged with three counts of Rape in the Second Degree. Count Two was voluntarily dismissed by the State before trial. At trial, the Family Court judge found Baker delinquent on Count One and acquitted him on Count Three. On appeal, Baker argued the judgment of delinquency for the one count of Rape in the Second Degree should be reversed because of evidentiary errors made by the Family Court judge at trial. The Delaware Supreme Court agreed that errors were made and reversal was required. View "Baker v. Delaware" on Justia Law

Minor J.S. appealed a dispositional order adjudging him a ward of the court pursuant to Welfare and Institutions Code section 602 and placing him on formal probation, subject to various terms and conditions. At the time of the incident that led to the charges against J.S., in October 2017, the victim, John Doe, was nine years old and lived with his grandmother in Contra Costa County, California. That month, a family friend and her son and two nephews, 12-year-old J.S. and his brother R.R., were temporarily staying at Doe's home. The family friend's nephews stayed in Doe's room with him. Doe woke up and turned on the light in his room. At that time, R.R. was still sleeping and J.S. was in the bathroom getting ready for school. When J.S. returned to the bedroom, he told Doe to suck his "private part," and said that if Doe did not do it, J.S. would hurt Doe. J.S. exposed his penis and "showed" Doe what he wanted Doe to do. Doe was afraid that J.S. would hurt him, so he got on the ground and began to orally copulate J.S. Doe's grandmother discovered the pair; police were ultimately called. J.S. denied the sequence of events. On appeal, J.S. argued that certain probation conditions that permitted searches of his electronic devices and imposed limitations on his use of computers, the Internet, and social networking Web sites were unconstitutionally overbroad and should be stricken in their entirety. In the alternative, J.S. contended that the conditions at issue should have been stricken and the case remanded to allow the trial court to determine whether the conditions can be narrowly tailored to serve the state's interest in rehabilitation. Finding no abuse of discretion or other reversible error, the Court of Appeal affirmed. View "In re J.S." on Justia Law

Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law

The State of New Jersey charged fourteen-year-old D.M. with delinquency based on conduct which, if committed by an adult, would constitute first-degree aggravated sexual assault. The State alleged D.M. committed acts of sexual penetration against an eleven-year-old acquaintance, Z.Y. With the parties’ consent, the Family Part judge considered the lesser-related charge of third-degree endangering the welfare of a child. In this appeal, the issue presented for the New Jersey Supreme Court's review centered on whether a juvenile could be adjudicated delinquent for endangering the welfare of a child when the juvenile and his alleged victim were fewer than four years apart in age and the Family Part judge made no findings of sexual penetration, force, or coercion. An Appellate Division panel reversed the juvenile adjudication, reasoning that the Legislature did not intend for the endangering statute, N.J.S.A. 2C:24-4(a)(1), to support a delinquency adjudication based on a juvenile’s sexual contact with another minor fewer than four years younger than he, in the absence of a finding of sexual penetration, force, or coercion. The New Jersey Supreme Court did not concur with the Appellate Division panel’s construction of the endangering statute. Although the Legislature may decide that statute: "nothing in the current text of N.J.S.A. 2C:24-4(a)(1) precludes the adjudication in this case. We decline to rewrite the statute’s plain language in this appeal." The Court concluded, however, that the Family Part court’s adjudication had to be reversed: "When the court, at the disposition hearing, disavowed critical aspects of its previously-stated factual findings and characterized its decision to adjudicate D.M. under the lesser-related offense as a humanitarian gesture, it undermined its determination as to both offenses. In this extraordinary setting, it is unclear whether the State met its burden to prove beyond a reasonable doubt that D.M. violated N.J.S.A. 2C:24-4(a)(1)." View "New Jersey in the Interest of D.M." on Justia Law

The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err.Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law

J.M., a minor, was adjudged a ward of the court and placed on probation with various terms and conditions after he made a false report that a bomb or other explosive device would be placed in his school. In the published portion of the opinion, the Court of Appeal held that J.M.'s words were not protected by the First Amendment to the United States Constitution, and Penal Code section 148.1, subdivision (c) is not unconstitutionally overbroad. The court held that subdivision (c) of section 148.1 criminalizes the malicious communication of knowingly false information about placement of a bomb or other explosive, and such utterances are not constitutionally protected speech. View "People v. J.M." on Justia Law