Justia Juvenile Law Opinion Summaries

Defendant Paul Gallimore pleaded guilty to committing three robberies on three consecutive days in different locations at age 16. These convictions pushed his criminal history category to VI under USSG § 4B1.4(c)(2) which, in turn, set his guideline imprisonment range at 188 to 235 months. The statutory range, because of the Armed Career Criminal Act (“ACCA”) enhancement, was fifteen years to life. The ACCA sentencing enhancement applied to defendants with three prior convictions for committing violent felonies on separate occasions. Defendant appealed the calculation of the sentence he received (200 months imprisonment), arguing he committed these robberies on one occasion (which would have reduced the range of his sentence). The Tenth Circuit disagreed, finding that the time between each robbery and their different locations both decisively differentiated "occasions" here. View "United States v. Gallimore" on Justia Law

Petitioner Anthony Jones pleaded guilty to first-degree burglary and armed robbery, crimes he committed at the ages of sixteen and seventeen, respectively. Pursuant to subsection 63-19-20(1), South Carolina's definitional statute of chapter nineteen in the Juvenile Justice Code, the circuit court had jurisdiction over Jones's charges, rather than the family court. The circuit court judge sentenced Jones to ten years in prison for armed robbery and fifteen years for first-degree burglary, with the sentences to run concurrently. Jones did not file a direct appeal. Instead, he filed an application for post-conviction relief ("PCR") on several grounds, including a challenge to the constitutionality of subsection 63-19-20(1). After a hearing, the PCR court dismissed the application, finding the constitutional challenge was not a cognizable PCR claim and, even if it were, the statute was constitutional. The South Carolina Supreme Court concluded Jones properly brought this challenge in his PCR application and subsection 63-19-20(1) was constitutional. However, in keeping with prior decisions regarding sentencing juveniles, the Court held circuit court judges had to consider the mitigating factors of youth as identified in Aiken v. Byars when sentencing. "Consideration of these factors can be done at sentencing; therefore, a separate Aiken hearing is not required." Accordingly, the Supreme Court affirmed in part and reversed in part. View "Jones v. South Carolina" on Justia Law

Petitioner Jon Smart and his co-defendant, Stephen Hutto, were in custody at a Department of Juvenile Justice detention facility near Rimini in Clarendon County in August 1999 when they brutally murdered a citizen volunteer who graciously allowed the boys to work on his family farm under his supervision as a part of their rehabilitation. Smart and Hutto then stole the man's truck and drove it on a violent crime spree. After Horry County Police officers stopped them for a traffic violation and discovered the truck was stolen, Smart and Hutto led officers on a thirty-mile high-speed chase during which Smart fired shots at pursuing law enforcement vehicles. Smart was sixteen years old. Smart pled guilty in 2001 to murder, armed robbery, grand larceny, criminal conspiracy, and escape. The plea court sentenced him to life in prison for the murder. The issue his appeal presented for the South Carolina Supreme Court's review centered on whether a juvenile sentenced to life in prison, bore any burden of proof or persuasion when seeking resentencing under Aiken v. Byars, 765 S.E.2d 572 (2014). The Supreme Court held there was no such burden—on either party—and the resentencing court did not impose such a burden. View "South Carolina v. Smart" on Justia Law

Fox TV obtained permission from Superintendent Dixon to film scenes for the television series, Empire, at the Cook County Juvenile Temporary Detention Center. Fox used the Center’s outdoor yard, visitation room, medical office, and certain living spaces for five days and returned to film retakes on seven additional days. During filming, several housing pods housed more detainees than the Center’s policy suggested; some detainees exercised indoors instead of in the outdoor yard; some classes were moved; and the Center postponed or canceled some extra‐curricular activities and held visitation hours in a smaller room.Three detainees filed a proposed class action lawsuit under 42 U.S.C. 1983. The district court granted Dixon partial summary judgment on qualified immunity grounds because the plaintiffs had not shown “a clearly established right to be free of the arguably modest disruptions” but did not dismiss state law claims. The court reasoned that Dixon acted as the detainees’ guardian and had a fiduciary duty to “protect [them] from harm.” Under the holding, Dixon would only be entitled to sovereign immunity on the state law breach of fiduciary duty claim if he proved that he did not violate the detainees’ constitutional rights. On interlocutory appeal, the Seventh Circuit held that Dixon is immune from suit under the Illinois State Lawsuit Immunity Act. The alleged wrongful conduct arose from decisions Dixon made within the scope of his authority. View "T. S. v. County of Cook" on Justia Law

After Appellant Cameron Moon was certified in juvenile court to stand trial as an adult, the juvenile court ordered his case transferred to the district court for adult criminal proceedings. Appellant then filed a pretrial application of writ of habeas corpus challenging the transfer. The district court denied relief, so Appellant took an interlocutory appeal. The Court of Appeals reversed the district court’s order denying relief, concluding the State had failed to establish the necessary statutory criteria for waiver of juvenile jurisdiction and transfer into the adult criminal court. As a result, the appellate court remanded the case with instructions to dismiss the prosecution for lack of jurisdiction. The Texas Court of Criminal Appeals granted the State's petition for discretionary review to consider several issues related to the juvenile court's transfer order including whether the court of appeals erred to hold that such a challenge was even cognizable in pretrial habeas. However, the Court concluded that, even if Appellant’s claims were cognizable in a pretrial habeas proceeding, the court of appeals lacked the authority to entertain Appellant’s interlocutory appeal. Accordingly, the Court of Criminal Appeals reversed the court of appeals’ judgment and remanded to that court for an order dismissing Appellant’s appeal as premature. View "Ex parte Moon" on Justia Law

After defense counsel raised concerns regarding seventeen-year-old A.T.C.’s competency, the magistrate ordered a competency evaluation. A psychologist from the Office of Behavioral Health (“OBH”) subsequently evaluated A.T.C. and determined that he was incompetent but restorable. Shortly thereafter, based on OBH’s evaluation, the magistrate entered a preliminary finding that A.T.C. was incompetent but restorable. The State moved for a second competency evaluation, asking the magistrate to allow a psychologist of the State's choosing to evaluate A.T.C. Over defense counsel’s objection, the magistrate granted the motion. The psychologist retained by the State evaluated A.T.C. and concluded that he was competent to proceed. Following a contested hearing at which OBH’s psychologist, the psychologist retained by the State, and a third psychologist all testified, the magistrate found that A.T.C. was competent to proceed. Defense counsel timely petitioned the juvenile court for review, but was unsuccessful. Counsel then petitioned the Colorado Supreme Court. Addressing whether a juvenile in a delinquency case could seek interlocutory review of a magistrate’s competency finding in the juvenile court as a matter of first impression, the Supreme Court concluded a magistrate’s finding of competency pursuant to section 19-1-108(3)(a.5), C.R.S. (2022), was subject to review in the juvenile court under section 19-1-108(5.5). View "Colorado in the interest of: A.T.C." on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

G.C. brings this interlocutory appeal from a family division order denying his request for youthful-offender status. The State charged youth with felony sexual assault in October 2021. On appeal, G.C. argued the evidence did not support the court’s finding that there was insufficient time to meet youth’s treatment and rehabilitation needs. After review of the family division order, the Vermont Supreme Court found no reversible error and affirmed. View "In re G.C." on Justia Law

In May 2022, the juvenile court granted a motion to transfer defendant minor T.A. from juvenile court to a court of criminal jurisdiction. T.A. argued the Court of Appeal should remand so the juvenile court could reconsider its ruling in light of recent ameliorative changes to the law enacted by Assembly Bill No. 2361 (2021-2022 Reg. Sess.). The State conceded that the changes applied retroactively to a minor, like T.A., whose case was not final when they took effect. Nevertheless, the State argued, no remand was necessary here because there was no reasonable probability the juvenile court would have reached a different result under the amended law. To this, the Court of Appeal agreed and therefore affirmed. View "In re T.A." on Justia Law

Minor S.S. (minor) appealed an order transferring him from the juvenile court to a court of criminal jurisdiction, pursuant to former Welfare and Institutions Code section 707.1. Minor contended: (1) the juvenile court’s findings were not supported by substantial evidence; and (2) subsequent legislation applies retroactively and requires reversal because the juvenile court did not comply with new requirements for transfer hearings. The State conceded the second argument. The Court of Appeal agreed with the parties that the new law applied retroactively and therefore reversal and remand was appropriate for an amenability hearing in compliance with the new law. View "In re S.S." on Justia Law