Justia Juvenile Law Opinion Summaries

Iowa Const. art. I, section 17 does not categorically prohibit a district court form sentencing a juvenile offender to a minimum term of incarceration without the possibility of parole, provided that the court only imposes the sentence after a complete and careful consideration of the relevant mitigating factors of youth.Defendant, who was a juvenile at the time of his offense, was resentenced to a minimum term of incarceration of seventeen and one-half years for sexual abuse in the second degree. Defendant appealed, arguing that any minimum term of incarceration without the possibility of parole is unconstitutional. The court of appeals affirmed the sentence. The Supreme Court remanded for resentencing, holding that, while the Iowa Constitution does not require abandonment of the practice at issue, the district court abused its discretion in this case by imposing a sentence of incarceration without parole eligibility. View "State v. Roby" on Justia Law

In 1999, LeBlanc, then age 16, raped a 62- year-old woman. In 2003, a state trial court sentenced him to life in prison. Virginia had abolished traditional “parole” for felony offenders and enacted its “geriatric release” program, which allows older inmates to receive conditional release under some circumstances. In 2010, the Supreme Court held, in Graham v. Florida, that the Eighth Amendment prohibits juvenile offenders convicted of nonhomicide offenses from being sentenced to life without parole and that states must give defendants “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” LeBlanc sought to vacate his sentence in light of Graham. The state court denied the motion, citing the Supreme Court of Virginia’s decision in Angel v. Commonwealth, that Virginia’s geriatric release program satisfies Graham’s requirement of parole for juvenile offenders: “The regulations for conditional release under this statute provide that if the prisoner meets the qualifications for consideration contained in the statute, the factors used in the normal parole consideration process apply to conditional release decisions under this statute.” LeBlanc filed a federal habeas petition, 28 U.S.C. 2254. The Supreme Court reversed the Fourth Circuit’s grant of relief. The Virginia trial court’s ruling, resting on the Virginia Supreme Court’s ruling in Angel, was not objectively unreasonable in light of existing Supreme Court authority. View "Virginia v. LeBlanc" on Justia Law

Voters passed Proposition 57 on November 8, 2016, effective the next day. As relevant here, the new law eliminated the State’s ability to directly file criminal charges against a juvenile defendant in a court of criminal jurisdiction (Adult Court). Jeremy Walker was charged with two counts of attempted premeditated murder and one count of active participation in a gang. He was seventeen at the time of the alleged crimes. A jury found Walker guilty as charged. The jury also found firearm and gang enhancements true. The trial court sentenced Walker to 80 years to life in prison. In May 2015, the Court of Appeal ruled that the trial court erred in admitting certain evidence at Walker's trial and reversed his convictions. In September 2015, the remittitur issued in Walker's appeal. Since the issuance of the remittitur, Walker waited for retrial. While waiting, Proposition 57 became effective, and Walker moved to transfer his case from Adult Court to Juvenile Court. Walker argued Proposition 57 applied retroactively to his case. The trial court agreed; the State appealed, and the Court of Appeal reversed, finding Proposition 57 did not apply here. View "California v. Super. Ct." on Justia Law

The Georgia Supreme Court found that appellant Avery Bryant’s trial counsel was ineffective for failing to challenge the sufficiency of the police warrant leading to Bryant’s arrest. The warrant in question did not adequately describe the items police intended to seize, therefore the search was presumptively unreasonable and unconstitutional, “the warrant here did not simply omit a few items from a list of many to be seized, or misdescribe a few of several items . . . , the warrant did not describe the items to be seized at all.” Bryant had been convicted by jury of malice murder, felony murder, aggravated assault with a deadly weapon, possession of a firearm during the commission of a felony, and possession of a pistol by a person under age 18. On appeal, he argued ineffective assistance of counsel, and that the trial court erred in instructing the jury. In light of the ineffective assistance claim, the Georgia Supreme Court did not address Bryant’s remaining claims of error, and remanded the case for further proceedings. View "Bryant v. Georgia" on Justia Law

Yididya Woldemichael pleaded guilty to armed robbery and other charges for his role in the robbery and beating of a pizza delivery woman. He filed a petition for habeas corpus, which was granted on grounds that his trial counsel was ineffective for failing to advise Woldemichael that inculpatory custodial statements could have been suppressed. Woldemichael was 14 years old at the time of the police interview. The Warden appealed the grant of habeas relief, arguing that the statements were voluntary and would have been admissible at trial and, thus, counsel’s performance was not deficient. The Georgia Supreme Court agreed with the habeas court that Woldemichael’s statements to police were subject to suppression. But because the habeas court assumed, without separate analysis, that recorded statements that Woldemichael made to a co-defendant during a break in police questioning also were subject to suppression, it remanded for the habeas court to analyze the admissibility of those statements in the first instance. View "Oubre v. Woldemichael" on Justia Law

In 2006, Guy Lucero was convicted by jury for multiple offenses arising from a drive-by shooting. He was tried as an adult. The trial court sentenced Lucero to consecutive term-of-years prison sentences for each count, aggravated as crimes of violence, resulting in an aggregate sentence of eighty-four years. The court of appeals affirmed Lucero’s convictions and sentences on direct appeal. In 2010, the U.S. Supreme Court held in Graham v. Florida, 560 U.S. 48 (2010), that the Eighth Amendment to the U.S. Constitution prohibited the imposition of a life without parole sentence on a juvenile non-homicide offender, concluding that states must “give defendants like Graham some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Subsequently, Lucero filed a motion pursuant to Rule 35(b) of the Colorado Rules of Criminal Procedure seeking reduction of his sentence. As relevant here, Lucero argued that his sentence must be reduced under Graham to meet constitutional standards, because an eighty-four-year sentence imposed on a juvenile carried the same implications as a sentence of life without parole. The trial court denied the motion; the court of appeals affirmed. The Colorado Supreme Court determined "Graham" and "Miller" did not apply here, and therefore, did not invalidate Lucero's aggregate term-of-years sentence. The Court also rejected Lucero’s argument that the court of appeals erred in treating his claim as one under Rule 35(c). View "Lucero v. Colorado" on Justia Law

In 2000, Atorrus Rainer was convicted by jury on two counts of attempted first-degree murder, two counts of first-degree assault, one count of first-degree burglary, one count of aggravated robbery, and crime of violence. He was seventeen at the time of the charged offenses, and he was charged as an adult. Rainer was sentenced to forty-eight years for each attempted murder charge, thirty-two years for each assault charge, and thirty-two years each for the charges of burglary and aggravated robbery. The sentences for the two counts of attempted murder were subsequently ordered to run concurrently, as were the sentences for the two counts of assault, resulting in an aggregate sentence of 112 years. Following the U.S. Supreme Court’s decision in Graham v. Florida, 560 U.S. 48 (2010), which categorically banned sentences of life without parole for juveniles who were not convicted of homicide, Rainer moved the district court to vacate the sentence, arguing that his aggregate term-of-years sentence was the functional equivalent of life without parole and therefore unconstitutional under "Graham." The district court denied the motion. On appeal, the court of appeals reversed, concluding that, because Rainer would be eligible for parole at about age seventy-five, thus ineligible for parole within his expected lifetime, he had no meaningful opportunity to obtain release and was unconstitutional under "Graham" and the subsequent case of Miller v. Alabama, 132 S. Ct. 2455 (2012). The Colorado Supreme Court determined "Graham" and "Miller" did not apply here, and therefore, did not invalidate Rainer's aggregate term-of-years sentence. View "Colorado v. Rainer" on Justia Law

In 1995, Cheryl Armstrong was convicted by jury on two counts of second-degree murder under a complicity theory. She was sixteen at the time of the charged offenses, and was tried as an adult. Armstrong was sentenced to forty-eight years in prison on each count, to be served consecutively, resulting in an aggregate sentence of ninety-six years. Following the U.S. Supreme Court’s decision in Graham v. Florida, 560 U.S. 48 (2010), which categorically banned sentences of life without parole for juveniles who were not convicted of homicide, Armstrong moved the district court to vacate the sentence, arguing that her aggregate term-of-years sentence was the functional equivalent of life without parole and therefore unconstitutional under "Graham." The district court denied Armstrong’s motion. On appeal, the court of appeals affirmed, concluding that, because Armstrong will be eligible for parole at about age sixty, she has a meaningful opportunity to obtain release, and her sentence thereby complied with "Graham" and the subsequent case of Miller v. Alabama, 132 S. Ct. 2455 (2012). The Colorado Supreme Court determined "Graham" and "Miller" did not apply here, and therefore, did not invalidate Armstrong's aggregate term-of-years sentence. View "Armstrong v. Colorado" on Justia Law

In 2006, a jury convicted Alejandro Estrada-Huerta of second-degree kidnapping and sexual assault. Estrada-Huerta was seventeen at the time he was charged, and he was tried as an adult. The trial court sentenced Estrada-Huerta to twenty-four years for the kidnapping conviction and sixteen years to life for each count of sexual assault. The sexual assault sentences were ordered to run concurrently with each other but consecutive to the kidnapping sentence, resulting in an aggregate sentence of forty years to life in the custody of the Department of Corrections. Estrada-Huerta moved to vacate his sentences, arguing his aggregate term-of-years sentence was the functional equivalent of life without parole and was therefore unconstitutional under Graham v. Florida, 560 U.S. 48 (2010). The court of appeals affirmed, concluding that, because Estrada-Huerta would be eligible for parole at age fifty-eight, he had a meaningful opportunity to obtain release, therefore his sentence complied with “Graham” and the subsequent case of Miller v. Alabama, 132 S. Ct. 2455 (2012). The Colorado Supreme Court affirmed the appellate court’s result, though on different grounds. The Court found that “Graham” and “Miller” did not apply in this matter; Estrada-Huerta was not sentenced to life without the possibility of parole: he received consecutive terms for three separate convictions. View "Estrada-Huerta v. Colorado" on Justia Law

Justin B. was found delinquent for committing criminal sexual conduct with a minor in the first degree. The family court imposed the mandatory, statutory requirement that he register as a sex offender and wear an electronic monitor, both for life. Justin B. claimed the mandatory imposition of lifetime registration and electronic monitoring on juveniles was unconstitutional. Finding no reversible error, the Supreme Court affirmed the family court. View "In the Interest of Justin B." on Justia Law