Justia Juvenile Law Opinion Summaries

The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements.The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

Sixteen-year-old E.G. was petitioned as a delinquent for having committed the offenses of falsifying physical evidence, and possession of drugs. The petitions also alleged that E.G.’s case had been screened and deemed inappropriate for diversion because E.G. was “being petitioned as a delinquent for a felony level charge, and has several previous police contacts where he was involved in disturbances, criminal mischief and reckless conduct.” E.G. filed a motion to suppress, among other things, “all evidence obtained in violation of [his] right against self-incrimination.” Specifically, he contended that he had been subjected to custodial interrogation by police without having been informed of his rights in accordance with Miranda and New Hampshire v. Benoit, 126 N.H. 6 (1985). The trial court denied the motion. Considering the totality of the circumstances of the encounter, the New Hampshire Supreme Court concluded a reasonable juvenile in E.G.’s position would not have believed himself to be in custody, and therefore, that E.G. was not in custody for Miranda purposes when he made the incriminating statements to the officer. View "In re E.G." on Justia Law

The Ninth Circuit affirmed the district court's denial of a petition for habeas relief challenging a sentencing enhancement for a prior nonjury juvenile conviction and for a gang-related crime. Petitioner argued that the evidence supporting the gang enhancement was constitutionally insufficient under Jackson v. Virginia, 443 U.S. 307 (1979), and that the enhancement for his nonjury juvenile conviction violated Apprendi v. New Jersey, 530 U.S. 466 (2000).The panel held that it was objectively unreasonable to conclude that the evidence was sufficient for a reasonable jury to find the robbery was committed "in association with" a gang; but it was not objectively unreasonable to conclude that the evidence was sufficient for a reasonable jury to find the robbery was committed "for the benefit of" a gang. The panel also held that the juvenile conviction claim was procedurally barred, and the sentencing enhancements based on nonjury juvenile convictions did not violate any clearly established federal law as determined by the United States Supreme Court. View "Johnson v. Montgomery" on Justia Law

The Supreme Court held that using a prior juvenile adjudication of delinquency for the commission of an offense that would have been felonious assault if committed by an adult as an element of the offense of having a weapon under disability, as set forth in Ohio Rev. Code 2923.13(A)(2), does not violate due process under the Ohio or United States Constitutions.Appellant was indicted on one count of having a weapon while under a disability. The alleged disability stemmed from Appellant’s prior adjudication of delinquency as a juvenile for committing a felonious assault. Appellant filed a motion to dismiss, asserting that his juvenile adjudication could not be used as a predicate for criminal conduct under section 2923.13(A)(2). The trial court denied the motion to dismiss. Appellant was subsequently convicted and sentenced. The court of appeal affirmed. The Supreme Court affirmed, holding that a previous juvenile adjudication may be an element of the weapons-under-disability offense set forth in section 2923.13(A)(2) without violating due process. View "State v. Carnes" on Justia Law

Plaintiffs challenged Michigan’s statutory scheme for resentencing individuals who were convicted of first-degree murder and received mandatory sentences of life without parole for acts they committed as children. Plaintiff’s 2016 amended complaint (SAC) addressed the Supreme Court’s decisions in Miller v. Alabama (2012), and Montgomery v. Louisiana, (2016), and Michigan’s 2014 amendments to its juvenile sentencing scheme. The SAC included allegations that Michigan’s policies and procedures governing parole deny Plaintiffs a meaningful opportunity for release in violation of the Eighth and Fourteenth Amendments (Count IV); that deprivation of Plaintiffs’ good time and disciplinary credits in Section 769.25a(6) violates the Ex Post Facto Clause (Count V); and Defendants have failed to provide the Plaintiffs with access to programming, education, training, and rehabilitation opportunities in violation of the Eighth and Fourteenth Amendments (Count VI). The Sixth Circuit reversed the dismissal of Counts IV, V, and VI. On remand, the district court granted Plaintiffs summary judgment on Count V and class certification, and ordered permanent injunctive relief that prohibited Defendants from enforcing or applying the credit elimination. The Sixth Circuit affirmed, finding that Mich. Comp. Laws 769.25a(4)(c), which was enacted in 2014 and eliminates credits for individuals who were sentenced to mandatory life without parole for juvenile first-degree murder convictions, unconstitutional. View "Hill v. Snyder" on Justia Law

A jury convicted fourteen-year-old Lawrence Montoya for the New Year’s Day murder of a teacher from his school. After serving over thirteen years in prison, Montoya brought post-conviction claims for ineffective assistance of counsel and actual innocence. He sued several detectives involved in the investigation and trial, claiming they were responsible for his wrongful conviction pursuant to 42 U.S.C. 1983. Specifically, Montoya claimed the Detectives instigated a malicious prosecution against him, coerced his confession in violation of the Fifth Amendment, and subjected him to false arrest. The Detectives appealed when the district court held qualified immunity and absolute testimonial immunity did not shield the Detectives from liability and denied their motion to dismiss. After review, the Tenth Circuit held qualified immunity indeed shielded the Detectives from liability for Montoya’s malicious prosecution claim; both qualified immunity and absolute testimonial immunity barred Montoya’s Fifth Amendment claim. As for Montoya’s false arrest claim, the Court determined it lacked jurisdiction to consider whether or not qualified immunity applied. View "Montoya v. Vigil" on Justia Law

Defendant Tom Phung was 17 years old when he and fellow Tiny Rascal Gang (TRG) members, riding in about five cars, chased a fleeing vehicle containing eight rival gang members. A TRG member two cars ahead shot and killed one rival and seriously wounded a second. A jury convicted defendant, as an aider and abettor, of the lesser included crime of second degree murder (count 1), attempted murder (count 2), shooting at an occupied motor vehicle (count 3), and street terrorism (count 4). With respect to the first three crimes, the jury found true the allegations that defendant committed them for the benefit of a criminal street gang, and vicariously discharged a firearm causing great bodily injury and death. Defendant was sentenced to an aggregate state prison term of 40 years to life. While defendant's appeal was pending, the electorate passed Proposition 57, the Public Safety and Rehabilitation Act of 2016, which went into effect in November 2016. In March 2017, the Court of Appeal issued an opinion affirming the judgment against defendant. Defendant petitioned for review before the California Supreme Court. While that petition was pending, another panel of the Court of Appeal issued an opinion holding Proposition 57 operated retroactively under the rule announced in In re Estrada, 63 Cal.2d 740 (1965). Defendant’s counsel, however, was unaware of the filing of the concurrent appellate opinion, and did not raise the issue before the California Supreme Court. The Supreme Court denied review, following which the Court of Appeal issued a remittitur. Defendant moved to recall the remittitur on the ground that his counsel had provided ineffective assistance of counsel in failing to raise the retroactivity of Proposition 57 to his own case. Defendant’s counsel admitted the error. The motion was granted, the remittitur recalled, and supplemental briefing was ordered. The Court of Appeal ultimately affirmed defendant's conviction, but concluded Proposition 57 applied retroactively to defendant. Therefore, the Court reversed and remanded this case for a transfer hearing and resentencing. View "California v. Phung" on Justia Law

J.B., a juvenile, appealed the Superior Court’s order affirming the juvenile court's order adjudicating him delinquent. J.B. was charged for the first-degree murder and homicide of an unborn child in connection with the shooting death of his stepmother inside their family home on the morning of February 20, 2009. J.B. argued that there was insufficient evidence to support his adjudication of delinquency beyond a reasonable doubt for these offenses, and, alternatively, that the juvenile court’s adjudication was against the weight of the evidence. The Pennsylvania Supreme Court's careful review of the evidentiary record in this matter compelled its conclusion that the evidence introduced at his adjudicatory hearing was indeed insufficient, as a matter of law, to establish his delinquency for these offenses beyond a reasonable doubt. As a result, the Court reversed the Superior Court’s order which affirmed the juvenile court’s order of disposition for these offenses. View "In The Interest of J.B.; Appeal of: J.B." on Justia Law

In the sexual assault trial of fourteen-year-old “Alex,” the family court admitted into evidence the "tender-years" exception to the hearsay rule: the video-recorded statement that seven-year-old “John” gave to police, in which he alleged that Alex had sexually touched him on a school bus. John, who suffered from severe developmental disabilities, who during out-of-court and in-court questioning was unable to distinguish between fantasy and reality, and who was declared incompetent as a witness by the court, was permitted to testify pursuant to the incompetency proviso of N.J.R.E. 803(c)(27). The State recalled John to the stand. He had difficulty answering simple questions. For example, he stated “It’s right,” if the prosecutor referred to a spider as a flower, and in response to a leading question, indicated that the color black might be red. John stated that Alex, whom he identified in the courtroom, touched him on “my clothes, my pee-pee and my butt.” However, John stated that a little boy named Alex sat near him and that the little boys and big boys were separated on the bus. The family court adjudicated Alex delinquent. Alex appealed. The Appellate Division held that John was effectively unavailable for cross-examination, and therefore the admission of his statement to the detective violated Alex’s federal confrontation rights. The panel did not address any state-law evidentiary claims and remanded to the family court to assess whether the State’s remaining evidence was sufficient to prove the adjudication beyond a reasonable doubt. The Court granted the State’s petition for certification. The New Jersey Supreme Court reversed Alex’s delinquency adjudication on state-law grounds, concluding John's video-recorded statement was not admissible because the statement did not possess a sufficient probability of trustworthiness to justify its introduction at trial under N.J.R.E. 803(c)(27). Striking the recorded statement from the record did not leave sufficient evidence in the record to support, on any rational basis, the adjudication of delinquency against Alex. View "New Jersey in the Interest of A.R." on Justia Law

Minor A.R. (the Minor) challenged a dispositional order committing him to the California Department of Corrections and Rehabilitation, Division of Juvenile Justice (hereafter, DJJ). At the time of the disposition hearing, the Minor was 18 years old. His history with the juvenile justice system began when he was 13 years old, and a petition was first filed against him. In 2012, he admitted two counts of residential burglary. and was declared a ward. Since then, he would be charged with various property crimes, culminating with burglary, robbery and use of a deadly weapon. He admitted to several probation violations, leading to the commitment order at issue here. The Minor argued the juvenile court abused its discretion in committing him to DJJ, on the grounds there was no substantial evidence that a less restrictive placement would be inappropriate or ineffective. He also argued the court erred by applying his custody credits to the overall maximum term of confinement, instead of the lower maximum term set by the court. In a supplemental brief, Minor argued there was no substantial evidence of probable benefit from the DJJ commitment, citing a recently decided case, In re Carlos J., 22 Cal.App.5th 1 (2018). The Court of Appeal rejected these contentions and affirmed the judgment. View "In re A.R." on Justia Law