Justia Juvenile Law Opinion Summaries

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

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