Justia Juvenile Law Opinion Summaries

The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting.Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

Because third degree sexual assault is not a lesser-included offense of first degree sexual assault, the juvenile court erred in adjudicating Jordan B. based on its finding that he committed third degree sexual assault when the only law violation alleged in the petition was first degree sexual assault.The county attorney filed a petition asking the juvenile court to adjudicate Jordan as a juvenile who committed an act that would constitute a felony pursuant to Neb. Rev. Stat. 43-247(2). The felony alleged was first degree sexual assault, as described in Neb. Rev. Stat. 28-319. The juvenile court found that the State failed to prove Jordan committed acts constituting first degree sexual assault as charged. Nevertheless, the court raised sua sponte the “lesser included offense” of third degree sexual assault and adjudicated Jordan as a child within the meaning of section 43-247(1). The Supreme Court reversed, holding that the juvenile court adjudicated Jordan on grounds for which he had no notice, in violation of the Due Process Clauses of the Nebraska and United States Constitutions. View "In re Interest of Jordan B." on Justia Law

During seven weeks in 2002, Malvo (then 17 years old) and Muhammad, the “D.C. Snipers,” murdered 12 individuals, inflicted grievous injuries on six others, and terrorized the area with a shooting spree. The two were apprehended while sleeping in a car. A loaded rifle was found in the car; a hole had been “cut into the lid of the trunk, just above the license plate, through which a rifle barrel could be projected.” At the time, a Virginia defendant convicted of capital murder, who was at least 16 years old at the time of his crime, would be punished by either death or life imprisonment without the possibility of parole. A jury convicted Malvo of two counts of capital murder but declined to recommend the death penalty. He was sentenced to two terms of life imprisonment without parole. Malvo later pleaded guilty in another Virginia jurisdiction to capital murder and attempted capital murder and received two additional terms of life imprisonment without parole. The Supreme Court subsequently held that defendants who committed crimes when under the age of 18 cannot be sentenced to death; cannot be sentenced to life imprisonment without parole unless they committed a homicide that reflected their permanent incorrigibility; and that these rules were to be applied retroactively. The Fourth Circuit concluded that Malvo’s sentences must be vacated because the retroactive constitutional rules for sentencing juveniles were not satisfied. The court remanded for resentencing to determine whether Malvo qualifies as a rare juvenile offender who may, consistent with the Eighth Amendment, be sentenced to life without the possibility of parole because his “crimes reflect permanent incorrigibility” or whether those crimes instead “reflect the transient immaturity of youth,” so that he must receive a lesser sentence. View "Malvo v. Mathena" on Justia Law

A jury convicted Tia Marie-Mitchell Skinner, and Kenya Hyatt were convicted by jury: Skinner, for first-degree premeditated murder, conspiracy to commit murder and attempted murder for acts committed when she was seventeen years old; Hyatt for first-degree felony murder, armed robbery, conspiracy to commit armed robbery, and possessing a firearm during the commission of a felony for acts committed when he was seventeen years old. At issue before the Michigan Supreme Court was whether MCL 769.25 violated the Sixth Amendment because it allowed the decision whether to impose a sentence of life without parole to be made by a judge, rather than by a jury beyond a reasonable doubt. The Supreme Court held that MCL 769.25 did not violate the Sixth Amendment because neither the statute nor the Eighth Amendment required a judge to find any particular fact before imposing life without parole; instead, life without parole was authorized by the jury’s verdict alone. Therefore, the Court reversed the judgment of the Court of Appeals in Skinner and affirmed the part of Hyatt that held that “[a] judge, not a jury, must determine whether to impose a life-without-parole sentence or a term-of-years sentence under MCL 769.25.” However, the Court reversed the part of Hyatt that adopted a heightened standard of review for life-without-parole sentences imposed under MCL 769.25 and that remanded this case to the trial court for it to “decide whether defendant Hyatt is the truly rare juvenile mentioned in [Miller v Alabama, 567 US 460; 132 S Ct 2455; 183 L Ed 2d 407 (2012)] who is incorrigible and incapable of reform.” No such explicit finding is required. Finally, the Supreme Court remanded both of these cases to the Court of Appeals for it to review defendants’ sentences under the traditional abuse-of-discretion standard of review. View "Michigan v. Skinner" on Justia Law

At issue in this case was when public school students are entitled to Miranda warnings at school.B.A., who was thirteen years old, was escorted from a school bus and questioned in a vice-principal’s office in response to a bomb threat on a bathroom wall. Three officers wearing police uniforms hovered over B.A. and encouraged him to confess. B.A. moved to suppress the evidence from his interview, arguing that he was entitled to Miranda warnings because he was under custodial interrogation and officers failed to secure waiver of his Miranda rights under Indiana’s juvenile waiver statute, Ind. Code 31-32-5-1. The juvenile court denied the motion and found B.A. delinquent for committing false reporting and institutional criminal mischief. The Supreme Court reversed B.A.’s delinquency adjudications, holding (1) B.A. was in police custody and under police interrogation when he made the incriminating statements; and (2) therefore, B.A.’s statements should have been suppressed under both Miranda and Indiana’s juvenile waiver statute. View "B.A. v. State" on Justia Law

The Supreme Court affirmed the finding of the district court juvenile session that B.H. was incompetent to stand trial and dismissing the charges against him.B.H. was arrested for first-degree robbery and murder that occurred before he sustained severe injuries in an automobile accident. The Commonwealth moved to transfer B.H.’s case to circuit court. B.H. moved for a competency evaluation. The district court granted B.H.’s motion for a competency evaluation, conducted a competency hearing, and found B.H. incompetent to stand trial and unlikely to attain competency in the foreseeable future. The court then dismissed the charges without prejudice. On appeal, the court of appeals held that the Commonwealth had waived its right to contest any error by failing to object to the competency determination at any stage of litigation prior to discretionary review with the court of appeals. The Supreme Court affirmed, holding (1) the juvenile session of the district court had subject matter jurisdiction to conduct a competency hearing, and the Commonwealth waived its right to object to lack of particular case jurisdiction; and (2) the federal Constitution and the laws of the Commonwealth support holding competency hearings, if necessary, prior to transfer proceedings. View "Commonwealth v. B.H." on Justia Law

V.D., a worker at the Pittsburg Marina, saw G.B. with other young men near the maintenance yard, through a cyclone fence. He went inside a building where he could see them through an open door approximately 30 feet away. V.D. saw G.B., standing, while the others were sitting, dancing and waving a gun in the air. About five minutes later, police arrived, detained the young men, and discovered a shotgun and a revolver in the area where the young men had been. V.D. identified G.B. as the person who had been holding the gun. Officer Baker and V.D. both testified that G.B. was wearing white, but photographs of the individuals detained by police show him wearing black. G.B. was placed on juvenile probation after the court sustained allegations he possessed a concealable firearm (Penal Code section 29610). The court of appeal affirmed in part, rejecting an argument that the jurisdictional finding must be reversed because the eyewitness identification was unreliable. The court struck a probation condition requiring that G.B. “have peaceful contact only with all law enforcement” as unconstitutionally vague and narrowed a condition that G.B. stay away from any school campus unless enrolled to be consistent with state law concerning visiting school grounds. View "In re G.B." on Justia Law

The issue before the New Jersey Supreme Court in this matter centered on the admissibility of evidence procured from a home after police officers’ warrantless entry. A man was attacked at a bus stop in Willingboro and his cell phone was stolen. He and a police officer tracked the phone’s location to a nearby house using a phone tracking application. Several officers arrived at the house, and one spotted the stolen cell phone’s case through a window. When no one responded to their knocks on the door, the officers entered the house through an unlocked window. Once inside, they performed a protective sweep to determine whether the suspect was inside, and they found defendant, J.A., then seventeen years of age, under the covers of a bed. Shortly thereafter, defendant’s mother and brother arrived home. After the officers explained their investigation, defendant’s mother consented to a search of the house, and defendant’s brother voluntarily retrieved the stolen phone. Defendant was later charged with second-degree robbery for theft of the phone. Defendant moved to suppress the evidence, arguing that the officers’ entry into his home was unconstitutional because the officers entered without a warrant and there were no circumstances that would justify an exception to the warrant requirement. The trial court denied defendant’s motion to suppress, finding that although the officers’ search procedure may have been imprudent, it was ultimately defendant’s brother - without any coercion or duress from law enforcement - who retrieved the cell phone. The Appellate Division affirmed. The Supreme Court disagreed with the appellate panel’s determination that the officers’ warrantless entry was justified by the claimed exigency faced by the officers. However, the Court agreed defendant’s brother’s actions did not constitute state action and were sufficiently attenuated from the unlawful police conduct. Because we find that the brother’s independent actions operated to preclude application of the exclusionary rule to the evidence, the Court did not reach the question of defendant’s mother’s consent to search. Accordingly, the Court modified and affirmed the judgment of the Appellate Division. View "New Jersey in the Interest of J.A." on Justia Law

Minor, age 15, fell asleep in class, admitted he smoked marijuana the night before, and acquiesced to being searched, volunteering that he had a knife. The assistant principal found a folding pocket knife with a three-inch blade, rolling papers, and lighters. The Napa County DA filed a wardship petition (Welfare and Institutions Code 602) alleging a misdemeanor. Minor admitted the offense. The matter was continued. Two weeks later, Minor was arrested for smoking marijuana. The court declared Minor a ward of the court, placed him on probation, to be served in his mother’s home, and prohibited knowingly using or possessing alcohol or controlled substances, with a testing requirement. A second petition alleged that Minor tested positive for, and admitted using, marijuana and tested positive for Xanax. Two months later, another petition alleged that Minor failed to attend school, used marijuana, was discharged from a treatment program for noncompliance, and admitted using alcohol. Minor admitted using marijuana and alcohol. Before the dispositional hearing, the probation officer reported Minor had tested negative for controlled substances, was doing well in school, and had begun working. The treatment program advised that Minor was “doing very well.” The court continued him as a ward with a new probation condition allowing searches of his electronic devices and requiring him to disclose necessary passwords. The court of appeal struck the electronics search condition as unconstitutionally overbroad. View "In re D.B." on Justia Law

On the evening of January 12, 2017, Deputy Slawson was on duty at the Barstow Sheriff’s Department. At about 7:30 p.m., she was asked by a fellow deputy to watch a juvenile he had detained (minor R.W.) during a stolen vehicle investigation until her mother arrived to pick her up. The department had a policy which required minors in sheriff’s custody to be kept at the station for their safety until they could be released to their parent or another authorized adult. At the time she was turned over to Deputy Slawson’s custody, minor was no longer under investigation and no charges were being filed against her. Deputy Slawson escorted minor into the report-writing room and told her to have a seat until her mother arrived. As Deputy Slawson was doing paperwork on an unrelated matter, R.W. began speaking to her about the vehicle theft. R.W. said she stole the car, and she wanted to speak with the deputy who made the initial traffic stop and arrested the driver. R.W. asked to use Deputy Slawson’s personal cell phone to call the deputy, but Deputy Slawson refused. Minor became frustrated and increasingly impatient. Deputy Slawson then asked R.W. some basic questions about the case. When it became clear from R.W.'s responses that she had no involvement in the car theft, Deputy Slawson told minor that she did not need to lie to make herself a suspect in that case. R.W. got upset, grabbed her bags, and walked out of the room; she refused to comply with the deputy's commands to return. Another female deputy helped Deputy Slawson stop R.W. from leaving, and a third deputy eventually came to assist as well. R.W. resisted the deputies’ efforts, and she was handcuffed. R.W. was seated back in the report-writing room but was not arrested. After about 10 minutes, the handcuffs were removed. R.W.'s mother arrived 15 to 20 minutes later and took custody. Deputy Slawson issued R.W. a citation for resisting a peace officer, and a juvenile court subsequently found true the allegation that minor violated Penal Code section 148(a)(1). R.W. appealed her conviction, arguing insufficient evidence to support the juvenile court’s finding, because her custody was unlawful at the time Deputy Slawson restrained her from leaving. Finding no reversible error, the Court of Appeal affirmed the conviction. View "In re R.W." on Justia Law