Justia Juvenile Law Opinion Summaries

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

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

In 2013 and 2014, minor Y.A. had two petitions filed against her alleging offenses for unrelated incidents. For each petition, she was adjudged a ward of the juvenile court and placed on probation. Y.A. satisfactorily completed the terms of probation for only the offense alleged in the later-filed petition, which was then dismissed and all records pertaining to it sealed. Records relating to the prior petition were not sealed. The issue in this appeal was whether, under Welfare and Institutions Code section 786, a juvenile court could seal the records pertaining to a prior petition against a minor when the minor satisfactorily completed probation for an offense alleged in a later-filed petition. Based on the plain language of the statute, the Court of Appeal concluded it could not. View "In re Y.A.." on Justia Law

In 2010, 15-year-old Turner fired a gun at a group of young men, killing Allen, and grazing two others. Turner knew the victims from high school. A jury convicted Turner of second degree murder (Pen. Code, 187(a)), and two counts of attempted murder, and found true the allegations that Turner, personally used a firearm and personally inflicted great bodily injury. The court sentenced Turner to an aggregate state prison term of 84 years-to-life. The court of appeal affirmed the convictions, but modified the sentence, so that Turner will be entitled to a parole hearing after 25 years. The court upheld the trial court’s refusal to instruct the jury on the theories imperfect self-defense and justifiable homicide based on self-defense; its use of the instructions on a kill zone theory. The court also rejected a claim of ineffective assistance of counsel based on trial counsel’s failure to raise the issue of cruel and unusual punishment below and failure to present readily available mitigating evidence in support of a lesser sentence. View "People v. Turner" on Justia Law

In 2010, 15-year-old Turner fired a gun at a group of young men, killing Allen, and grazing two others. Turner knew the victims from high school. A jury convicted Turner of second degree murder (Pen. Code, 187(a)), and two counts of attempted murder, and found true the allegations that Turner, personally used a firearm and personally inflicted great bodily injury. The court sentenced Turner to an aggregate state prison term of 84 years-to-life. The court of appeal affirmed the convictions, but modified the sentence, so that Turner will be entitled to a parole hearing after 25 years. The court upheld the trial court’s refusal to instruct the jury on the theories imperfect self-defense and justifiable homicide based on self-defense; its use of the instructions on a kill zone theory. The court also rejected a claim of ineffective assistance of counsel based on trial counsel’s failure to raise the issue of cruel and unusual punishment below and failure to present readily available mitigating evidence in support of a lesser sentence. View "People v. Turner" on Justia Law