Justia Juvenile Law Opinion Summaries

Montgomery was 17 years old in 1963, when he killed a deputy in Louisiana. The jury returned a verdict of “guilty without capital punishment,” which carried an automatic sentence of life without parole. Nearly 50 years later, the Supreme Court decided, in Miller v. Alabama, that mandatory life without parole for juvenile offenders violates the Eighth Amendment’s prohibition on cruel and unusual punishments. The trial court denied his motion for relief. His application for a supervisory writ was denied by the Louisiana Supreme Court, which had previously held that Miller does not have retroactive effect in state collateral review. The Supreme Court reversed. Courts must give retroactive effect to new watershed procedural rules and to substantive rules of constitutional law. Substantive constitutional rules include “rules forbidding criminal punishment of certain primary conduct” and “rules prohibiting a certain category of punishment for a class of defendants because of their status or offense.” Miller announced a substantive rule of constitutional law, which is retroactive because it necessarily carries a significant risk that a defendant faces a punishment that the law cannot impose. A state may remedy a Miller violation by extending parole eligibility to juvenile offenders. This would neither impose an onerous burden nor disturb the finality of state convictions and would afford someone like Montgomery, who may have evolved from a troubled, misguided youth to a model member of the prison community, the opportunity to demonstrate the truth of Miller’s central intuition—that children who commit even heinous crimes are capable of change. View "Montgomery v. Louisiana" on Justia Law

The case centered Section 6105 of the Pennsylvania Uniform Firearms Act of 1995. Although a Section 6105 violation, by default, is graded as a misdemeanor of the first degree, subsection (a.1)(1) elevated the offense grade to a felony of the second degree where the defendant was “convicted” of any felony offense enumerated in subsection (b). In 2011, Appellee was convicted, among other things, of a Section 6105 offense, apparently based upon his possession of a firearm and the fact of a previous juvenile adjudication in 2005 for conduct which would give rise to an aggravated assault conviction if committed by an adult. Prior to sentencing, the prosecution apparently took the position that the finding of delinquency should be considered a “conviction” for purposes of the subsection (a.1)(1) enhancement. On appeal, however, the Superior Court vacated the sentence and remanded for resentencing. The intermediate court explained that the term “conviction” carried a discrete legal connotation that is not generally understood to encompass juvenile adjudications. The Supreme Court granted review to determine whether juvenile adjudications of delinquency qualify as “convictions” for purposes of grading within a particularized sentencing regime. The Court held that the concept of convictions, as embodied in Section 6105, did not encompass juvenile adjudications. View "Pennsylvania. v. Hale" on Justia Law

Appellant Chase C. (a minor) was charged with resisting, delaying, or obstructing a peace officer. An adjudication hearing was held, at which the juvenile court found the allegation against Chase to be true. The court adjudged Chase a ward of the court and placed him on formal probation for one year or until Chase's 18th birthday, whichever was longer. These proceedings were instituted over an incident in May 2014, when a San Diego Sheriff's Deputy was conducting a foot patrol through Turtle Park, in the Forest Ranch area of San Diego. The deputy was not in full uniform at the time, but was wearing either an external raid vest with "Sheriff" written on it, or a Sheriff shirt with patches. The deputy was approached by a group of middle school children, who told him that two high school aged children had tried to sell them drugs. The issue this case presented for the Court of Appeal's review centered on a novel issue regarding whether Chase (once the deputy caught up with a group of teens matching the middle schoolers' descriptions) who allegedly urged his cohorts not to cooperate with a police investigation, rose to the level of a violation of Penal Code1 section 148. This case called for the Court to determine when a refusal to cooperate with police becomes unlawful interference with police activity under section 148. The Court concluded that refusal to cooperate only becomes criminal when it obstructs lawful police activity. Here, substantial evidence did not support the trial court's finding with regard to section 148(a)(1), and reversed. View "In re Chase C." on Justia Law

Minor J.B. appealed a condition of probation that the trial court imposed after he was convicted of petty theft. On appeal to the Court of Appeal, J.B. argued the trial court unconstitutionally imposed a condition of probation that required him to permit searches of and disclose all passwords to his electronic devices and social media sites. Because there was no evidence connecting the juvenile’s electronic device or social media usage to his offense or to a risk of future criminal conduct, the Court of Appeal concluded the condition was unreasonable. Accordingly, the Court modified the judgment to strike this condition. View "In re J.B." on Justia Law

M.A., then 13 years old, fought with her 14-year-old brother and cut him with a kitchen knife. M.A. was adjudicated delinquent of several offenses and ordered to register under the Murderer and Violent Offender Against Youth Registration Act, 730 ILCS 154/1. M.A. argued that the registration provisions violated her rights to substantive and procedural due process and equal protection. The Appellate Court rejected the substantive due process claim, but found the registration provisions unconstitutional for violating procedural due process and equal protection. The Illinois Supreme Court reinstated the registration requirement. Current dangerousness is not relevant to the duty to register, so M.A. did not have a due process right to a hearing to address that issue. The Act requires registration solely based upon the fact of conviction or adjudication, which M.A. had a procedurally safeguarded opportunity to contest during her juvenile adjudication proceedings. M.A. did not challenge her adjudication as a juvenile delinquent on appeal. Given that the charges for which M.A. is required to register would be felonies if M.A. committed those acts as an adult, and that those charges require a finding that the offender caused “great bodily harm, permanent disability, or disfigurement,” there is a rational relationship between M.A.’s registration and protection of the public. View "In re M.A." on Justia Law

Petitioners were 13-year-old girls who were dependents of the juvenile court. While they were residing at the Polinsky Children's Center, they knocked over a vending machine and took items from inside it. When staff confronted them, petitioners fled but later returned to the Center. Staff then reported the incident to police, who arrested petitioners and booked them into Juvenile Hall. The district attorney filed petitions in the juvenile court alleging petitioners committed two misdemeanors, petty theft and vandalism. The district attorney asked the court to declare them wards. The probation officer prepared detention reports recommending petitioners be detained in Juvenile Hall, on the unexplained grounds they were likely to flee the court's jurisdiction and such detention was necessary for the protection of person or property and of petitioners. The reports included detention screening forms that showed no grounds for mandatory secure detention and that petitioners' risk assessment scores did not warrant discretionary secure detention. Petitioners promptly challenged the detention orders by filing petitions for peremptory writs of mandate in the first instance directing the juvenile court to vacate the orders. The Court of Appeal treated the petitions as petitions for writs of habeas corpus. The Court of Appeal agreed with the parties that the juvenile court erred by ordering petitioners' detention in Juvenile Hall pending further hearing. The juvenile court made no findings regarding its decision to order petitioners' continued detention in Juvenile Hall. Accordingly, the Court of Appeal granted petitioners' petitions. View "In re Bianca S." on Justia Law

Relator was 14 years old when he committed murder in 1998. Relator was waived into adult court and convicted of aggravated murder. The court sentenced relator to life imprisonment with a 30-year mandatory minimum period of incarceration. After relator had served roughly half of that period, he obtained a “second look” hearing under ORS 420A.203. The trial court entered a preliminary order of conditional release, but the state appealed that order to the Court of Appeals. At issue in this mandamus proceeding was the trial court’s related “direction” to the Department of Corrections, pursuant to ORS 420A.206(1)(a), requiring it to prepare a proposed release plan. Relator sought, and the Supreme Court issued, an alternative writ of mandamus ordering the department to comply with the trial court’s direction or to show cause for not doing so. The department, however, contended that its obligation to comply was automatically stayed under ORS 138.160. The Supreme Court disagreed and ordered the department to comply with the trial court’s direction to prepare and submit a proposed plan of release. View "Oregon ex rel Walraven v. Dept. of Corrections" on Justia Law

In 2005, Martinez, Vallejo, and 47 others were indicted for crimes committed while they were members of the Milwaukee chapter of the Latin Kings gang organization. Martinez and Vallejo pled guilty to a RICO offense, 18 U.S.C. 1962, and admitted to engaging in predicate racketeering activities, including a 2003 murder. Vallejo, who was 17 years old at the time, and Martinez, who was 16, each fired several shots at the victim. Martinez also pled guilty to attempted murder of a rival gang member; Vallejo’s plea agreement included two attempted murders. All of the attempted murders occurred while the defendants were under the age of 18. In both cases, the court imposed the “maximum sentence”—life in prison.. Neither Martinez nor Vallejo filed a direct appeal. In 2012, the Supreme Court held, in Miller v. Alabama, that the Eighth Amendment prohibits the imposition of a mandatory life sentence without the possibility of parole for juveniles. The Seventh Circuit affirmed the district court’s denial of their motion to vacate, set aside, or correct their sentences under 28 U.S.C. 2255. Martinez and Vallejo’s life sentences were imposed after an individualized sentencing, and not by statutory mandate,and did not violate Miller. View "Vallejo v. United States" on Justia Law

Defendant Terrence Roberson was charged with armed robbery and attempted second-degree murder for offenses which allegedly occurred in 2012, when the defendant was sixteen years old. The issue this case presented for the Supreme Court's review centered on whether the Juvenile Court’s dismissal of defendant's case for expiration of the time period for adjudication provided in the Children’s Code prevented the District Attorney from later obtaining a grand jury indictment against defendant and bringing the case to District Court. In this case, the District Court quashed the defendant’s indictment on the basis of the Juvenile Court’s prior dismissal of the juvenile petition with prejudice. The Court of Appeal reversed the District Court’s grant of the motion to quash. Finding no reversible error in that decision, the Supreme Court affirmed. View "Louisiana v. Roberson" on Justia Law

Defendant was serving 35 years to life after a jury convicted him as an adult of attempted murder and other charges for robbing and shooting a woman in the face when he was 15 years old. In this appeal, defendant argued, the State conceded, and the Court of Appeal agreed, that a three-year enhancement for great bodily harm under Penal Code section 12022.71 was unauthorized and should have been stayed. This reduced his sentence to 32 years to life. Defendant also contended his overall sentence constitutes cruel and unusual punishment because the sentencing court did not comply with the requirements in "Miller v. Alabama" (132 S.Ct. 2455 (2012)) and "California v. Caballero," (55 Cal.4th 262(2012)) that it consider his youth and consequent reduced culpability and impose a sentence reflecting these considerations. While the Court of Appeal recognized that considerations of defendant's youth did not, and by statute could not, play a major part in determining his sentence, the sentence passed constitutional muster because he “shall be eligible for release on parole by the board during his or her 25th year of incarceration at a youth offender parole hearing” pursuant to section 3051. View "California v. Garcia" on Justia Law