Justia Juvenile Law Opinion Summaries

The Eighth Circuit reversed and remanded the district court's grant of summary judgment in a suit against employees of a juvenile home, concluding that the district court erred by holding as a matter of law that defendants were entitled to qualified immunity. Plaintiff alleged that defendants violated his constitutional rights by housing him in prolonged solitary confinement, failing to educate him, and allowing him to be sexually abused. In this case, the district court addressed only the fact of juvenile court supervision in determining that defendants were entitled to qualified immunity, and its opinion did not contain sufficient detail to allow the court to review whether defendants were entitled to qualified immunity. View "Bradford v. Avery" on Justia Law

R.S. acknowledged that he did not object to two issues he raised on appeal to the Court of Appeal; the Court determined R.S. forfeited those issues. R.S. was found trespassing on school grounds as a nonstudent. Officers detained him after he became belligerent. One of the officers suffered a hairline fracture to his thumb during the struggle. R.S. was arrested in connection with a robbery outside of a Starbucks approximately two months later. At the police station, R.S. at first denied punching the victim in the head, later admitting to striking the victim. R.S. conceded that he attacked the victim to steal his iPhone. At the disposition hearing, the juvenile court imposed, among others, the following probation conditions: "Minor shall submit [his] person, property, or vehicle, and any property under [his] immediate custody or control to search at any time, with or without probable cause, with or without a search warrant, by any law enforcement officer or peace officers, probation officers, school officials or officers, and any other state security officers or agents engaged in the lawful performance of their duties [search condition]." "The minor shall not knowingly be in any privately owned vehicle with more than one person the minor knows or reasonably should know is under the age of 18 unless accompanied by a parent or legal guardian, a responsible adult, or with permission of the probation officer [supervision condition]." R.S. challenged these two conditions, arguing the search condition was unconstitutionally overbroad and vague while the supervision condition was unconstitutionally vague. Because he was making facial challenges to the conditions, R.S. argues his claims of error raised pure questions of law that the Court of Appeal should review. The Court disagreed, concluding R.S. forfeited these challenges by not raising them sooner. View "In re R.S." on Justia Law

The trial court complied with California Rules of Court, rule 5.651(b)(2)(D) by sufficiently considering I.V.'s educational needs. I.V. appealed a dispositional order adjudging him a ward of the court pursuant to Welfare and Institutions Code section 602 and placing him on formal probation, subject to various terms and conditions. On appeal, I.V. argued the juvenile court erroneously imposed a probation condition requiring him to enroll in the Reflections Day Center Treatment Program without making necessary findings about his special educational needs under Rule of Court 5.651(b)(2)(D). I.V. also argued that a probation condition allowing warrantless searches of his "person, property, vehicle, and any property under his/her immediate custody or control" was unconstitutionally vague and overbroad because it may encompass searches of his electronic devices and data. The Court of Appeal affirmed. View "In re I.V." on Justia Law

Sixteen-year-old defendant Adrian Vela and one of his fellow gang members confronted two suspected rival gang members. Vela’s accomplice pulled out a gun and shot the two victims, killing one of them. The prosecutor directly filed charges against Vela in “adult” criminal court. The jury found Vela guilty of murder, attempted murder, and found true the related firearm and gang allegations. Vela makes several interrelated claims of instructional error concerning accomplice liability. Vela also raises two constitutional challenges to his 72 years to life sentence. In the unpublished parts of its opinion, the Court of Appeal found the trial court committed no instructional errors. Further, Vela’s sentence did not violate either the equal protection clause or the Eighth Amendment. In the published portion of its opinion, the Court conditionally reversed the judgment: the electorate recently approved Proposition 57, which emphasized juvenile rehabilitation, prosecutors can no longer directly file charges against a minor in an “adult” criminal court. Vela was retroactively entitled to a transfer hearing because his case was not yet final on appeal. If, after conducting the hearing, the juvenile court judge determines that Vela’s case should be transferred to a court of criminal jurisdiction, then his convictions and sentence will be reinstated. But if the juvenile court determined that Vela was amenable to rehabilitation, and should remain within the juvenile justice system, then his convictions would be deemed juvenile adjudications. View "California v. Vela" on Justia Law

Defendant pleaded guilty to attempted murder. Defendant was sixteen years old at the time of the offense. Defendant was sentenced to twenty-five years in prison, including a mandatory minimum term of incarceration. Defendant was also ordered to pay $150,000 in mandatory restitution to the victim’s estate. Defendant was later resentenced and received immediate parole eligibility because the mandatory minimum period of incarceration had been deemed unconstitutional. The restitution was left in place. Defendant appealed, challenging the $150,000 in restitution to the victim’s estate. The Supreme Court affirmed, holding (1) the $150,000 mandatory restitution for juvenile homicide offenders is not facially unconstitutional; and (2) the $150,000 mandatory restitution was not unconstitutional as applied to Defendant. View "State v. Breeden" on Justia Law

Petitioner-appellant Keighton Budder was convicted by an Oklahoma jury of several violent nonhomicide crimes committed when he was sixteen years old. After sentence modification on direct appeal, he received three life sentences and an additional sentence of twenty years, all to run consecutively. He was not be eligible for parole under Oklahoma law until he served 131.75 years in prison. Budder filed a petition for writ of habeas corpus, arguing his sentence violated the Eighth Amendment. In support, he cited “Graham v. Florida,” (560 U.S. 48 (2010)), which held that sentencing juvenile offenders who have not committed homicide crimes to life in prison without a meaningful opportunity for release was unconstitutional. The district court denied Budder’s petition, and he appeals. The Tenth Circuit reversed and remanded with instructions to grant Budder’s petition. The Court found under the categorical rule clearly established in “Graham,” Budder’s sentence violated the Eighth Amendment. “The [Oklahoma Supreme Court’s] judgment was contrary to this clearly established Supreme Court precedent. Accordingly, we reverse and remand with instructions to grant Budder’s petition for writ of habeas corpus, to vacate Budder’s sentence, and to direct the State of Oklahoma to resentence Budder within a reasonable period.” View "Budder v. Addison" on Justia Law

Proposition 57 eliminated the State's ability to directly file charges against a juvenile offender in adult court and instead authorized the State to file “a motion to transfer the minor from juvenile court to a court of criminal jurisdiction.” Prior to the passage of Proposition 57, the State directly filed a complaint against real party in interest, a minor, in adult court under the authority of former section 707(d)(2) of the Welfare and Institutions Code. A preliminary hearing took place May 26, 2016; on June 10, 2016, the State filed an information charging real party in interest with felony violations of Penal Code sections 209(b)(1), 286(c)(2)(B), and 288a(c)(2)(B). On November 16, 2016, real party in interest filed a motion requesting “a fitness hearing in juvenile court pursuant to recently enacted legislation via Proposition 57.” After considering written opposition from the State, who argued Proposition 57 could not be applied to real party in interest's case retroactively, the trial court granted the motion on November 29, 2016. Noting that the issue was “novel,” the trial court stayed its order until December 20, 2016, so the State could seek appellate intervention. The State's petition in this case followed three days later, seeking an emergency stay and asserted there would be “widespread confusion and continued litigation” if the trial court's order in this case stood. In addition, the petition introduced evidence that there were 57 other direct-file cases pending, and that 10 motions to transfer to juvenile court had already been received. The Court of Appeal denied the State's petition and published this opinion because "we recognize that trial courts may need guidance deciding whether and how to apply Proposition 57 to cases that were directly filed in adult court before its passage. We caution that we need not and therefore do not opine about anything other than the retroactivity of the portion of Proposition 57 that requires the juvenile court to permit trial of a minor in an adult criminal court. We do not address the equal protection argument real party in interest advanced in his informal response. In addition, although the People asked for advice about how courts should handle direct-filed cases that are transferred to juvenile court and then back to adult court after a successful motion under Welfare and Institutions Code section 707, subdivision (a), we do not purport to guide trial courts regarding other procedural aspects of cases against juveniles now that Proposition 57 has passed. Any such issues are best left for cases that squarely present them." View "California v. Super. Ct." on Justia Law

The Court of Appeals, in a divided full-court (15-judge) decision, certified to the Georgia Supreme Court a single question of statutory construction: whether OCGA 15-11-521 (b) required dismissal with prejudice when the State neither filed a petition alleging juvenile delinquency within the applicable 30-day period nor seeks an extension of time in which to file such petition. At the time the Court of Appeals certified its question, the Supreme Court had granted petitions for certiorari in two other cases ("M.D.H." and "D.V.H.") to address the same question. The Court held in a single opinion that “if the State fails to file a delinquency petition within the required30 days or to seek and receive an extension of that deadline, the case must be dismissed without prejudice,” and thus affirming the decision in M.D.H. and reversing the decision in D.V.H. Because the answer to the certified question submitted by the Court of Appeals in this case “may be found in the decision of this [C]ourt in [another case,] we will not again undertake to consider the question[]submitted.” View "In the Interest of J.F." on Justia Law

Defendant, who was sixteen years old at the time of his arrest, was charged as an adult with robbery and aggravated assault. Defendant was subsequently interviewed by police in connection with an assault of a female. The day after he made a statement, Defendant was charged as an adult with residential burglary, sexual assault in the second degree, and aggravated assault. Defendant filed a motion to suppress the statement he made to police. The circuit court granted the motion to suppress, concluding that Defendant was unable to waive his right to counsel because he was in the custody of the Arkansas Department of Human Services at the time of the interview. The Supreme Court reversed, holding that the circuit court erred in its interpretation of Ark. Code Ann. 9-27-317(g) and therefore erred in granting Defendant’s motion to suppress. View "State v. Griffin" on Justia Law

In lieu of adjudging minor J.G. a ward of the court based on his commission of trespass and felony vandalism, the juvenile court granted minor deferred entry of judgment and placed him on probation with terms and conditions including payment of restitution to the victim. Because minor eventually satisfied the terms and conditions of his probation with the exception of ordered restitution, the juvenile court terminated probation, dismissed the wardship petition and converted the restitution order to a civil judgment. Minor appealed that order, arguing: (1) the Court of Appeal had jurisdiction to review the juvenile court’s order because the order was a judgment within the meaning of Welfare and Institutions Code section 800(a); (2) a juvenile court can only convert a restitution order to a civil judgment if it has adjudged a minor a ward of the court; and (3) the juvenile court misapplied the law in assessing minor’s ability to pay restitution. In the published portion of its opinion, the Court of Appeal concluded: (1) the challenged order was a judgment within the meaning of section 800(a) because the juvenile court rendered a final determination of the rights of the parties in the wardship proceeding; and (2) even if a juvenile court has not adjudged a minor a ward of the court, it can convert an unfulfilled restitution order to a civil judgment when it terminates a minor’s deferred entry of judgment probation and dismisses the wardship petition. In the unpublished portion of this opinion, the Court concluded: (3) minor has not established a misapplication of the law. Accordingly, the Court affirmed the juvenile court. View "In re J.G." on Justia Law