Justia Juvenile Law Opinion Summaries

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law

Sixteen-year-old M.H. used his smartphone to surreptitiously record a fellow high school student, Matthew B., in a school bathroom stall while Matthew was either masturbating or jokingly pretending to do so. The video, taken inside the bathroom, but about 20 feet away from the bathroom stall, did not show Matthew's face, but did reveal his distinctive socks and shoes, which were visible in the gap between the stall wall and the floor. M.H. uploaded the 10-second video to Snapchat with the caption, "I think this dude is jacking off [sic]." M.H. intended the video to be funny and to get a laugh. But about two weeks later, Matthew took his own life, stating in a suicide note, "I can't handle school anymore and I have no friends." The San Diego County District Attorney's Office filed a juvenile delinquency petition alleging M.H. engaged in an unauthorized invasion of privacy by means of a cell phone camera. The trial court found true the allegation that M.H. violated Penal Code section 647(j)(1). The trial court sentenced M.H. to probation on numerous conditions, including several restricting his use of social media. On appeal, M.H. argued: (1) no substantial evidence supported the juvenile court's finding that he had the requisite specific intent "to invade Matthew's privacy" as required by section 647(j)(1); (2) (raised for the first time on appeal) section 647(j)(1) incorporated by reference the elements of the tort of invasion of privacy, and assuming that to be true, he asserts there is a "newsworthy" defense that immunizes him from criminal liability in this case; and (3) (also for the first time on appeal) section 647(j)(1) violated his First Amendment rights. Finding no reversible error, the Court of Appeal affirmed. View "In re M.H." on Justia Law

A petition was filed with the juvenile court alleging that George F. committed a lewd and lascivious act upon a child under the age of 14, and that George willfully annoyed and molested a child under the age of 18. The State offered to dismiss count 1 if George admitted to count 2. George admitted to count 2 and the juvenile court found a factual basis for that admission. The court then granted the State's motion to dismiss count 1, declared George a ward of the court, and ordered him to juvenile probation on various terms and conditions. George appealed, contending that the conditions of his probation restricting his use of electronics or requiring the submission of those electronics to search were invalid under "California v. Lent (15 Cal.3d 481 (1971)) and (2) unconstitutionally overbroad. Finding no reversible error, the Court of Appeal affirmed. View "In re George F." on Justia Law

Petitioner D.C. appealed the denial of post-conviction relief (PCR), alleging that the change-of-plea hearing that preceded his adjudication of juvenile delinquency was constitutionally inadequate. The superior court held that the PCR statute did not apply to juvenile delinquency proceedings and that the only remedy available to petitioner was through 33 V.S.A. 5113 and Vermont Rule of Civil Procedure 60(b), but that route was foreclosed because petitioner’s claim was untimely raised. On appeal, petitioner argued that the case was not moot, despite the fact he was over the age of majority at the time of his appeal (and no longer committed to state custody), and that the PCR statutes permitted juveniles to collaterally attack their adjudications. After review, the Vermont Supreme Court agreed, reversed the superior court’s order dismissing petitioner’s PCR complaint, and remanded for further proceedings. View "In re D.C." on Justia Law

K.H.-H., a 17-year-old male, was charged with assault with sexual motivation after he forced himself on C.R., a female acquaintance who attended the same high school. The issue this case presented on appeal involved whether a juvenile disposition condition requiring K.H.-H. to write an apology letter to the victim violated his constitutional free speech rights. After review, the Supreme Court held that it did not. View "Washington v K. H.-H." on Justia Law

A complaint was filed in juvenile court alleging that A.G. was delinquent for engaging in conduct that, if committed by an adult, would have constituted aggravated robbery and kidnapping, with firearms specifications as to each. A.G. admitted to the allegations in the complaint. The juvenile court found the allegations proved beyond a reasonable doubt and ordered that A.G. be committed to the Department of Youth Services for minimum terms of one year for each of the aggravated robbery and kidnapping adjudications. A.G. appealed, arguing that the juvenile court erred in failing to merge his adjudications for aggravated robbery and kidnapping as “allied offenses of similar import” and that his trial counsel was ineffective for failing to raise the allied-offenses issue. The Court of Appeals denied relief, concluding that the aggravated robbery and kidnapping would constituted allied offenses of similar import under Ohio Rev. Code 2941.25 if committed by an adult but that criminal statutes do not apply in juvenile delinquency proceedings. The Supreme Court reversed, holding that juvenile courts must conduct the same double-jeopardy analysis in delinquency proceedings that other courts apply in adult criminal proceedings to protect a child’s right against double jeopardy. View "In re A.G." on Justia Law

In 2004, when Petitioner was sixteen years old, she and her boyfriend committed murder. Petitioner was convicted of second-degree murder with a weapon, which was classified as a life felony. The trial court sentenced Petitioner to life without parole without indicating what findings of aggravating or mitigating circumstances warranted imposition of the life-without-parole sentence as opposed to a term-of-years sentence under the sentencing guidelines then in place. After the United States Supreme Court decided Miller v. Alabama, Petitioner filed a motion for postconviction relief in the form of resentencing. The circuit court denied the motion. The Second District Court of Appeal affirmed, concluding that because Petitioner was sentenced under a discretionary sentencing scheme, Miller was inapplicable to Petitioner’s life-without-parole sentence. The Supreme Court quashed the Second District’s decision, holding that Miller applies to juvenile offenders whose sentences of life imprisonment without parole were imposed pursuant to a discretionary sentencing scheme when the sentencing court, in exercising that discretion, did not take into account the individualized sentencing considerations of a juvenile offender’s youth. View "Landrum v. State" on Justia Law

In 2012, seventeen-year-old appellant Isaiah Sweet shot and killed Richard and Janet Sweet. Richard and Janet had cared for Sweet since he was four years old, as his biological mother was unable to do. Richard was Sweet’s biological grandfather. Richard and Janet had been married for thirty years. Sweet was arrested three days after the murder. After being given Miranda warnings, Sweet described events leading to the murders, the details of the murders themselves, and his activities in the days after the murders. Sweet was charged and convicted on first-degree murder charges. While his maturity was debatable, the district court stressed that the crimes were premeditated. The district court felt that Sweet's proffered expert's characterization of Sweet’s possibility of rehabilitation as "mixed" was overly optimistic. Further, the district court found Sweet’s case was the rare case in which a sentence of life without the possibility of parole was warranted, as the murders were horrific and showed utter lack of humanity. The district court concluded that Sweet was currently, and will continue to be, a threat to society and that the interests of justice and community safety outweighed mitigating factors. Sweet was sentenced to life without the possibility of parole. The Supreme Court reversed and remanded for resentencing, finding that a sentence of life without the possibility of parole for a juvenile offender violated article I, section 17 of the Iowa Constitution. View "Iowa v. Sweet" on Justia Law

This case involved a challenge to a juvenile court’s decision to waive its jurisdiction over a 13-year-old boy who was alleged to have committed aggravated murder. Under the relevant statutes, ORS 419C.352 and ORS 419C.349, a youth under age of 15 who is alleged to have committed murder may be waived into adult court only if, at the time of the conduct, he or she “was of sufficient sophistication and maturity to appreciate the nature and quality of the conduct involved.” In this case, the evidence suggested that youth was of “average” sophistication and maturity for his age and was “just as effective” as peers of his age in understanding that his conduct was wrong. The juvenile court found that the statutory “sophistication and maturity” requirement had been satisfied. The Court of Appeals affirmed, holding that the “sophistication and maturity” provision required only an awareness of the physical nature and criminality of the conduct at issue. The Oregon Supreme Court agreed with the youth that the “sophistication and maturity” requirement was more demanding, and reversed both the appellate and juvenile courts. The case was remanded to the juvenile court for further proceedings. View "Oregon v. J. C. N.-V." on Justia Law

Michigan charged and tried the named plaintiffs as adults for acts they committed while under the age of 18. Each received a conviction for first-degree murder and a mandatory sentence of life in prison without the possibility of parole. In 2010, plaintiffs challenged the constitutionality of the Michigan statutory scheme that barred them from parole eligibility. Since then, the Supreme Court held in Miller v. Alabama (2012), “that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments,’” Michigan amended its juvenile offender laws in light of Miller, but made some changes contingent upon either the Michigan Supreme Court or the U.S. Supreme Court announcing that Miller applied retroactively, and the U.S. Supreme Court held in Montgomery v. Louisiana (2016), that Miller’s prohibition on mandatory life without parole for juvenile offenders is retroactive. The district court held, in 2013, that Miller should apply retroactively and issued an injunction requiring compliance with Miller. The Sixth Circuit vacated and remanded for consideration of remedies in the context of the new legal landscape and to determine whether class certification is required to extend relief to non-plaintiffs. View "Hill v. Snyder" on Justia Law