Justia Juvenile Law Opinion Summaries

In 2003, Murdock was convicted of first-degree murder and aggravated battery with a firearm. In connection with his post-conviction claim of ineffective assistance of counsel, a suppression hearing was held to determine whether Murdock's statements to the police were voluntary, given that Murdock was 16 years old and was without an attorney or other adult present. The Illinois Supreme Court affirmed denial of a motion to suppress. The federal district court denied habeas relief under 28 U.S.C. 2254, finding that the Illinois Supreme Court’s decision was not unreasonable. The Seventh Circuit affirmed: the court applied the correct test in a reasonable manner in finding that the totality of the circumstances indicated that Murdock gave his statements voluntarily. The court considered Murdock’s age, and that he did not have an attorney or other adult present, but found that he was able to understand and provide an adequate waiver of his rights. The court considered that Murdock was detained for approximately seven hours, but noted that the interview lasted only three hours and that Murdock was given the opportunity to eat and use the restroom. There was no evidence that the officers threatened him or otherwise created a coercive environment. The court found that Murdock did not appear to be under distress or frightened on a video recording. View "Murdock v. Dorethy" on Justia Law

The two defendants in this case were juveniles when they fatally shot their victims. Defendants were each convicted of first degree murder. Defendants were sentenced to natural life imprisonment under Ariz. Rev. Stat. 13-703, meaning they were not eligible for release. After Miller v. Alabama was decided, each defendant filed a petition for post-conviction relief under Ariz. R. Crim. P. 32.1(g). In each case, the trial court summarily denied relief, concluding that the sentencing court had complied with Miller and that any constitutional infirmity in Arizona’s sentencing scheme had been resolved by 2014 statutory amendments. The Supreme Court vacated the opinion of the court of appeals, reversed the trial court’s dismissal of the petitions for post-conviction relief, and remanded for further proceedings, holding that Defendants were entitled to evidentiary hearings on their Rule 32.1(g) petitions because they made colorable claims for relief based on Miller. View "State v. Valencia" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated robbery, three counts of rape, and other offenses. Defendant was fifteen years old at the time he committed the crimes. The trial court sentenced Defendant to the maximum prison term for each count. The sentence totaled 141 years in prison. At issue before the Supreme Court in this appeal was whether, pursuant to Graham v. Florida, a term-of-years prison sentence that exceeds a defendant’s life expectancy violates the Eighth Amendment’s prohibition against cruel and unusual punishments when it is imposed on a juvenile nonhomicide offender. The Supreme Court answered this question in the affirmative and remanded the cause to the trial court for resentencing, holding (1) Graham’s categorical prohibition of sentences of life imprisonment without the possibility of parole for juveniles who commit nonhomicide crimes applies to juvenile nonhomicide offenders who are sentenced to term-of-years sentences that exceed their life expectancies; and (2) therefore, Defendant’s 112-year sentence violates the Eighth Amendment. View "State v. Moore" on Justia Law

A complaint was filed in the juvenile court alleging that Appellant engaged in conduct that would be considered aggravated robbery if committed by an adult. Appellant was sixteen years old at the time of the alleged offense. The State filed a motion to transfer Appellant to the general division of the common pleas court to be tried as an adult pursuant to Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b), which provide for mandatory transfer of juveniles to adult court in certain circumstances. After a hearing, the juvenile court automatically transferred the case. Appellant moved to dismiss the ensuring indictment charging him with two counts of aggravated robbery with accompanying firearm specifications and transfer his case back to juvenile court, arguing that mandatory transfer of juveniles is unconstitutional. The trial court overruled the motion. Appellant subsequently entered pleas of no contest to the two counts of aggravated robbery. The court of appeals affirmed. The Supreme Court reversed, holding that mandatory transfer of juveniles to adult court without providing for the protection of a discretionary determination by the juvenile court judge violates juveniles’ right to due process. View "State v. Aalim" on Justia Law

Ray M. appealed an Imperial County juvenile court order denying his motion to conduct a new assessment under Welfare and Institutions Code section 241.11 and declaring him a delinquent ward under section 602. Ray filed his motion after the Kern County juvenile court determined he should be deemed a ward, and not a dependent, without providing notice to his dependency attorney or to the Imperial County court as required by section 241.1 and California Rules of Court, rule 5.512.2 Ray also argued, and the Imperial County Department of Social Services conceded, that the juvenile court erred at the outset of the dependency by failing to provide notice as required by the Indian Child Welfare Act (ICWA). The Court of Appeal agreed with Ray that because the Kern County juvenile court did not comply with the notice requirements set forth in section 241.1 and rule 5.512, the Imperial County juvenile court had the authority to revisit the Kern County court's assessment under section 241.1. Accordingly, the Court reversed the orders and remanded the case for the juvenile court assigned to hear Ray's dependency matter to conduct a new assessment under section 241.1 and, if Ray was deemed a dependent, to comply with the notice provisions of ICWA. View "In re Ray M." on Justia Law

In 1987, Defendant murdered his twelve-year-old sister. Defendant was fourteen years old at the time of the murder. Defendant was convicted of first degree murder and sentenced to life imprisonment. In 2013, Defendant filed a motion for postconviction relief, arguing that his sentence was cruel and unusual punishment in light of the U.S. Supreme Court decision in Miller v. Alabama. The district court vacated Defendant’s life sentence, finding that the sentence was within the parameters of the holding in Miller, that the rule in Miller applies retroactively, and that Defendant was therefore entitled to postconviction relief. The Supreme Court affirmed, holding that because the relevant sentencing scheme mandated life imprisonment without the possibility for parole, the district court was bound by Miller. Remanded for resentencing. View "State v. Thieszen" on Justia Law

In February 2014, Jason Dakota Baxter (who then was sixteen years old) was arrested and charged with aggravated sexual battery. Baxter was detained pending indictment and trial. About a month after his arrest, Baxter executed a written waiver of his entitlement to have his case presented to the grand jury within 180 days, and Baxter and the State filed the waiver with the superior court. In October 2014, however, Baxter filed a motion to transfer his case to juvenile court, asserting that his case had not been timely presented to the grand jury as required by OCGA 17-7-50.1 and that his waiver was ineffective. The superior court granted the motion, and the State appealed. The Court of Appeals affirmed, finding that presentation to the grand jury within 180 days of detention was an absolute requirement (unless the time was extended for good cause), that such presentation was essential to the jurisdiction of the superior court, and that parties could not by agreement, consent, or waiver confer jurisdiction upon a court that otherwise was without it. The Supreme Court reversed, finding that the Court of Appeals misunderstood OCGA 17-7-50.1 when it concluded that the statute did not permit a detained child to waive presentation within 180 days of the date of detention. For that reason, the Court of Appeals erred when it affirmed the transfer from the superior court to the juvenile court. Accordingly, the Supreme Court reversed the judgment of the Court of Appeals. View "Georgia v. Baxter" on Justia Law

In 2013 while he was in custody, investigators questioned a then- 18-year-old Tyler Estrada abut a Gwinnett County homicide. Estrada had been in custody in DeKalb County. At an evidentiary hearing, audio recordings of Estrada’s custodial statement were placed into evidence, the trial court determined that though Estrada invoked his right to counsel, he never waived his Miranda rights either in writing or verbally. Accordingly, the trial court granted Estrada’s motion to suppress the statement. The State appealed. Finding no reversible error to that suppression order, the Supreme Court affirmed. View "Georgia v. Estrada" on Justia Law

At issue in these cases was what happens when the State fails to file a petition alleging delinquency against a juvenile who was not detained within 30 days of the filing of the complaint or seek an extension of that deadline from the juvenile court. In In the "Interest of M.D.H.," (779 SE2d 433 (2015)), a panel of the Court of Appeals held that the failure to comply with section 15-11-521(b) required dismissal of the juvenile case, but the dismissal was without prejudice. Three days later, in "Interest of D.V.H.," (779 SE2d 122 (2015)), a different panel answered the same question the opposite way, concluding that a violation of section 15-11-121(b) required dismissal with prejudice. The Supreme Court granted certiorari in both cases, asking whether the Court of Appeals correctly applied OCGA section 15-11-521 (b). The Supreme Court held that if the State fails to file a delinquency petition within the required 30 days or to seek and receive an extension of that deadline, the case must be dismissed without prejudice. Accordingly, the Court affirmed the Court of Appeals’ judgment in M.D.H., and reversed the judgment in D.V.H. View "In the Interest of M.D.H." on Justia Law

Juvenile defendant Trey M. challenged his three convictions for felony harassment under RCW 9A.46.020. The Court of Appeals certified the issue to the Washington Supreme Court of whether the United States Supreme Court's decision in "Elonis v. United States," (135 S. Ct. 2001 (2015)) had any impact on the Washington Court's "reasonable person standard" for what constituted a "true threat" under the First Amendment to the United States Constitution. The Washington Supreme Court held that because "Elonis" expressly avoided any First Amendment analysis, it provided no basis for the Court to abandon its established First Amendment precedent. Accordingly, the Court affirmed. View "Washington v. Trey M." on Justia Law