Justia Juvenile Law Opinion Summaries

Plaintiffs-appellants, nineteen children in New York City’s foster care system, filed suit alleging “systemic deficiencies” in the administration of the City’s foster care system in violation of federal and state law. The named Plaintiffs moved to represent a class of all children who are now or will be in the foster care custody of the Commissioner of New York City’s Administration for Children’s Services and two subclasses. As remedies, they sought injunctive and declaratory relief to redress alleged class-wide injuries caused by deficiencies in the City’s administration—and the New York State Office of Children and Family Services’ oversight—of foster care. The district court denied Plaintiffs’ motion for class certification. Plaintiffs appealed, arguing that the district court erred in its analysis of the commonality and typicality requirements under Federal Rule of Civil Procedure 23(a).   The Second Circuit vacated the district court’s order denying class certification and remanded. The court held that the district court erred in its analysis of commonality and typicality under Rule 23. The court explained that the district court did not determine whether commonality and typicality exist with respect to each of Plaintiffs’ claims. Instead, it concluded that commonality was lacking as to all alleged harms because “Plaintiffs’ allegations do not flow from unitary, non-discretionary policies.” The court held that this approach was legal error requiring remand. Further, the court wrote that here, the district court largely relied upon its commonality analysis to support its finding that typicality was not satisfied. Thus, the deficiencies identified in its commonality inquiry can also be found in its handling of typicality. View "Elisa W. v. City of New York" on Justia Law

Petitioner Robert Miller, III was convicted of murdering eighty-six-year-old Willie Johnson. Following the murder, Petitioner—who was fifteen years old at the time—confessed four times: twice to his close friends and twice to law enforcement. All four confessions were admitted at trial, three without objection. This appeal centered around the voluntariness of Petitioner's fourth and final confession to two agents of the South Carolina Law Enforcement Division (SLED). After examining the totality of the circumstances surrounding the fourth confession, the South Carolina Supreme Court held that Petitioner's free will was not overborne, and his confession was voluntary. It therefore affirmed. View "South Carolina v. Miller" on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

In the midst of a group contacted by officers for smoking cannabis on the street, 16-year-old T.F.-G. witnessed first one and then another of his companions be restrained, searched, and made to sit on the curb as the officers worked their way through the group. T.F.-G. ran. Chased, tackled, and punched, he was arrested for resisting or delaying a peace officer (Pen. Code 148(a)). In a search incident to that arrest, the police found a loaded handgun in his pocket, which T.F.-G. was not licensed to carry.The court of appeal affirmed his convictions. The totality of the circumstances, establishing the existence of probable cause for his arrest for resisting or delaying a peace officer—the asserted basis for the eventual search that revealed his possession of a loaded handgun in public–indicated that a reasonable person in T.F.-G.’s position would have understood he was not free to leave. The court also rejected a Second Amendment facial challenge to the prohibition on the unlicensed public carrying of loaded firearms. Although California’s “good cause” licensing requirement is undisputedly unconstitutional under the Supreme Court’s 2022 “Bruen” decision, the unconstitutionality of a discrete licensing requirement does not render section 25850 facially unconstitutional. View "In re T.F.-G." on Justia Law

The San Bernardino County District Attorney filed a petition against defendant-appellant J.P. alleging he committed second degree robbery, assault with a firearm and carrying a loaded firearm not registered to him in a vehicle. A court found all three allegations true and sustained the petition. On appeal, J.P. argued Welfare and Institutions Code section 875 precluded commitment to a secure youth treatment facility (SYTF) unless the juvenile’s most recent offense was listed under Welfare and Institutions Code section 707(b), and J.P.’s most recent offense, the gun possession, was not such an offense. The State moved to dismiss the gun possession offense, to which J.P. objected, arguing that the court only had the power to strike the entre petition, not any single allegation. The court granted the State’s motion, dismissed the gun offense, and committed J.P. to an SYTF. Finding no reversible error in the trial court’s judgment, the Court of Appeal affirmed. View "In re J.P." on Justia Law

Defendant Christopher Rodriguez pleaded guilty to felony offenses committed when he was sixteen years old under a plea and disposition agreement, and following an amenability hearing, the district court imposed an adult sentence. Defendant appealed the amenability determination, and on its own motion, the Court of Appeals held that under the plea and disposition agreement, Defendant waived his right to appeal. The New Mexico Supreme Court granted certiorari to determine whether a juvenile waives the right to appeal an amenability determination by entering into a plea and disposition agreement. To this, the Court held that the right was not waived, reversed the Court of Appeals, and remanded the case to the Court of Appeals to decide Defendant’s appeal on the merits. View "New Mexico v. Rodriguez" on Justia Law

Juvenile D.J. appealed a circuit court's finding of delinquency based on a petition alleging that he committed harassment under RSA 644:4, I(b) (Supp. 2021). The victim told the juveniles that they were not supposed to be riding bicycles on the sidewalk. D.J. told the victim to go “f**k himself.” D.J. continued to yell at the victim, who testified that D.J. was “swearing, saying f**k this and f**k that and you’re nothing but an old man.” The victim yelled back at D.J. and asserted that he could do martial arts. D.J. got off his bicycle, provoked the victim to fight, and took off his shirt. The owner of a store across the street from this encounter observed the confrontation and, after it had gone on for approximately five minutes, she began to record it using her cellphone. The store owner also called the police. The incident lasted approximately eight minutes, until a patrol officer arrived at the scene. D.J. argued there was insufficient evidence to support the trial court’s finding, and that RSA 644:4, I(b) was unconstitutional as applied and on its face. Finding no reversible error, the New Hampshire Supreme Court affirmed. View "In re D.J." on Justia Law

Spectrum contracts with Michigan to house children who are ordered to be detained in facilities “similar to a prison setting.” The children are completely restricted in their movements. The state requires Spectrum to monitor them on a 24/7 basis. A court ordered the detention of 15-year-old Quintana at Spectrum’s facility on August 24, 2018. Quintana struggled with depression, anxiety, and difficulty sleeping, among other things. On September 11, 2018, Quintana took his life while alone in his bedroom. No one checked his room in the 45 minutes between the last time he was seen alive and when his body was found, violating a contractual requirement that Spectrum conduct “eye-on checks” every 15 minutes when the children are “outside of the direct supervision of staff.” Spectrum had a policy or custom of skipping many eye-on checks and falsifying supervision logs to reflect that the checks had been performed.Quintana’s estate sued Spectrum under 42 U.S.C. 1983, alleging that Spectrum functioned as a state actor and violated Quintana’s Eighth and Fourteenth Amendment rights. The Sixth Circuit reversed the dismissed the dismissal of the suit. The complaint contains adequate facts to establish that Spectrum is a state actor. Spectrum was allegedly engaged in a public function similar to a correctional institution, a traditionally exclusive state function. View "Nugent v. Spectrum Juvenile Justice Services" on Justia Law

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