Justia Juvenile Law Opinion Summaries

A jury found defendant Ezekiel Delgado guilty of two counts of first degree murder and one count of discharging a firearm at an occupied vehicle, found true a multiple-murder special circumstance and found that Delgado personally used a firearm, causing death. The trial court sentenced him to prison for a total unstayed term of 100 years to life. On appeal, defendant first claimed: (1) his inculpatory statements to the police should have been excluded on various grounds; (2) no substantial evidence supported the murder charge; (3) the trial court misinstructed on felony murder; (4) the trial court misinstructed on voluntary intoxication; (5) limits on the voluntary intoxication defense violate due process; and (6) he was entitled to a juvenile transfer hearing because of the passage of Proposition 57. The Attorney General conceded the last point. The Court of Appeal agreed with the parties that it had to remand for a juvenile transfer hearing, and agreed with defendant that, while on remand, the trial court should have the opportunity to consider exercising its newly acquired discretion regarding firearm enhancements. In the published portion of its opinion, the Court concluded the trial court erred in admitting some of defendant’s inculpatory admissions, but found the error harmless beyond a reasonable doubt. The Court disagreed with defendant’s remaining contentions of error, and remanded for further proceedings. View "California v. Delgado" on Justia Law

Based on acts that defendant Curtis Brooks committed when he was fifteen years old, prosecutors charged him as an adult with felony murder and other crimes. After a jury convicted Brooks on multiple counts, including the felony murder charge, the trial court imposed a mandatory life without the possibility of parole ("LWOP") sentence in accordance with Colorado’s then-applicable sentencing statutes. This case presented a question of whether Colorado’s recently enacted sentencing scheme for juvenile offenders who received unconstitutional mandatory sentences to life in prison without the possibility of parole (“LWOP”) violates the Special Legislation Clause of the Colorado Constitution. The Colorado Supreme Court concluded that it did not. View "Colorado v. Brooks" on Justia Law

The Supreme Judicial Court reversed the superior court judge’s denial of Defendant’s motion for resentencing, holding that Defendant, a juvenile convicted of armed home invasion, was sentenced to a mandatory minimum term exceeding that applicable to a juvenile convicted of murder without a hearing under Miller v. Alabama, 467 U.S. 460, 477-478 (2012), in violation of the requirements announced in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), and refined in Commonwealth v. Perez, 480 Mass. __ (2018) (Perez II), also decided today.Defendant was adjudicated a youthful offender on indictments charging armed home invasion and various related offenses and was sentenced to a mandatory minimum prison term of twenty years to twenty years and one day on the armed him invasion charge. Defendant later filed a motion for relief from unlawful restraint, which the juvenile court judge denied. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded to the juvenile court for resentencing, holding that Defendant’s sentence violated the proportionality requirement inherent in article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. Lutskov" on Justia Law

The Supreme Judicial Court held that its decision in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), requires sentencing judges to follow an individualized process that allows for the consideration of mitigating circumstances related to the juvenile's age and youthful characteristics before imposing a sentence with a longer period of incarceration prior to eligibility for parole than that applicable to a juvenile convicted of murder.In Perez I, the Supreme Judicial Court determined that Defendant, a juvenile, received a sentence for his nonhomicide offenses that was presumptively disproportionate under article 26 of the Massachusetts Declaration of Rights because the time he would serve prior to parole eligibility exceeded that applicable to a juvenile convicted of murder. On remand, a superior court judge held a hearing to determine whether, in light of the factors articulated in Miller v. Alabama, 467 U.S. 460, 477-478 (2012), the case presented extraordinary circumstances justifying a longer parole eligibility period. The judge then concluded that extraordinary circumstances were present and denied Defendant’s motion for resentencing. The Supreme Judicial Court vacated the order and remanded for resentencing, holding that the hearing judge erred in finding extraordinary circumstances in this case. View "Commonwealth v. Perez" on Justia Law

Defendant Richard Carter claimed cruel and unusual punishment in his sentence of 55 years to life in prison for a second-degree murder he committed at age 17, with personal use and discharge of a firearm causing death, possession of a firearm by a felon, and a prior strike conviction for robbery. The Attorney General acknowledged this sentence was the functional equivalent of a sentence of life in prison without possibility of parole (LWOP). To address defendant’s cruel and unusual punishment claim in the trial court, the trial court considered defendant’s youth in the context of considering whether to strike the prior conviction for purposes of three-strikes sentencing in furtherance of the interests of justice under Penal Code section 1385 and California v. Superior Court, 13 Cal.4th 497 (1996). This would have reduced the sentence to 40 years to life in prison. The trial court considered defendant’s youth but declined to strike the prior conviction, finding that although defendant was able to change, he was unwilling to do so. While this case was pending on appeal, the California Supreme Court held that a statute giving trial courts discretion to impose a sentence less than LWOP on a juvenile who commits special circumstance murder (Penal Code section 190.5) must be construed without a presumption in favor of LWOP (as previously construed by case law), in order that the statute not violate the Eighth Amendment. Other recent changes in law demand that the Court of Appeal not only vacate the sentence, but also conditionally reverse the conviction and remand to the trial court with directions to transfer the case to the juvenile court for a transfer hearing to determine the propriety of prosecution in adult criminal court had the case originally been filed in juvenile court. The Court so vacated and remanded for further proceedings. View "California v. Carter" on Justia Law

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