Justia Juvenile Law Opinion Summaries

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C. View "Hopkins v. State" on Justia Law

Plaintiff taught sixth-grade at a public school and met with a student’s parents about a threat the student had made against another student. He met the parents again after seeing the student beating another student. The father threatened a lawsuit and told plaintiff that an older son, who had assaulted the assistant principal, should have assaulted plaintiff. During a subsequent class, the student used an assignment to write a song with lyrics about stabbing plaintiff. The police liaison encouraged plaintiff to file criminal charges; under Illinois law declaring a knowing threat of violence against a person at a school is disorderly conduct, 720 ILCS 5/26-1(a)(13). School administrators feared a suit and were not supportive. After plaintiff filed charges, his evaluations went from satisfactory to unsatisfactory and administrators advised him that they would recommend that he not be rehired. Plaintiff resigned and filed suit, claiming retaliation for exercise of First Amendment rights. The district court granted summary judgment for defendants on the ground that the complaint was not protected by the First Amendment because it did not involve a matter of public concern. The Seventh Circuit reversed. Principles underlying the suit are well settled, which defeats claims of qualified immunity. View "Gschwind v. Heiden" on Justia Law

Parents of adopted sons, Austin, 16, and Ricky, 15, retained counsel to represent both. Each was charged with misdemeanor criminal sexual abuse of other boys under foster care in the household. After a joint bench proceeding, the petition against Ricky was denied. The circuit court found that an admission Austin purportedly made to police was sufficient to prove the charges. He was adjudicated a delinquent minor and sentenced to probation. The appellate court affirmed. The Supreme Court of Illinois reversed. A minor accused of delinquency has a non-waivable right to a defense attorney. In addition to representing accuseds jointly, counsel allowed presentation of videotaped statements of the alleged victims in lieu of live testimony, which could have been cross-examined. Counsel never argued that Austin’s purported statement was involuntary or sought to suppress it, despite evidence that Austin was questioned aggressively and had diminished mental capabilities. The representation was not the type of counsel guaranteed by due process and the Juvenile Court Act. The court and counsel indicated that they viewed the attorney as functioning as a guardian ad litem. There is a per se conflict where counsel attempts to perform as guardian ad litem and defense counsel in a delinquency proceeding. The evidence was sufficient that there was no double jeopardy bar to a new trial. View "In re Austin M." on Justia Law

This case required the Supreme Court to examine how Washington's juvenile justice laws interact with the Persistent Offender Accountability Act (POAA), also known as the "three strikes law." When Jorge Saenz was 15 years old, he agreed to waive juvenile court jurisdiction and transfer his case to adult court, where he pled guilty to two counts of felony assault in exchange for a moderately lower sentencing recommendation. As a result, seven years later he faced life in prison without the possibility of parole under the POAA. The issue for the Supreme Court's review concerned whether his waiver of juvenile court jurisdiction was valid and whether his case was properly transferred to adult court. The Court concluded that Saenz's waiver was invalid because there was virtually nothing in the record demonstrating that it was intelligently made or that Saenz was fully informed when he made it. Next, the Court held that Saenz's case was not properly transferred to adult court because the commissioner transferring the case failed to enter findings that transfer was in the best interest of the juvenile or the public as required by statute. On these facts, the Supreme Court held that Saenz's conviction could not be used as a "strike" to sentence him to spend the rest of his life in prison with no possibility of release. Instead, the Court affirmed the 561-month sentence imposed by the trial court. View "Washington v. Saenz" on Justia Law

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case. View "People v. W.B." on Justia Law

The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue. View "State v. Grigsby" on Justia Law

Ariz. Rev. Stat 8-238 requires juveniles charged with certain offenses and summoned to appear at an advisory hearing to submit to the investigating law enforcement agency a sample of buccal cells or other bodily substances for DNA testing and extraction. The penalty for failure to comply is revocation of release pending adjudication. In this case seven juveniles were separately charged with violations of offenses specified in section 8-238(A). Each was summoned to an advisory hearing, released, and ordered to submit a buccal sample to law enforcement within five days. In each case, the superior court rejected Fourth Amendment objections to the sampling order. The Juveniles jointly filed a special action in the court of appeals, which held that requiring the submission of DNA samples from juveniles for whom a probable cause determination has been made does not violate the Fourth Amendment. The Supreme Court vacated the opinion of the court of appeals, holding that the statutory scheme violated the Fourth Amendment prohibition against unreasonable searches and seizures. View "Mario W. v. Superior Court (Kaipio)" on Justia Law

The state filed a delinquency petition in the Juvenile Court for the Parish of Orleans charging Defendant with distribution of heroin in violation of La.R.S. 40:966(A)(1). After a hearing, the court adjudicated Defendant delinquent and ordered him committed to the custody of the Department of Public Safety and Corrections for a period not to exceed one year. On appeal, the Fourth Circuit set aside the juvenile court's adjudication and disposition order on grounds that "any rational trier of fact, after viewing all of the evidence favorably to the prosecution, must have a reasonable doubt as to the Defendant's guilt." The Supreme Court granted the state's application for review and reversed the decision because the court of appeal erred in substituting its appreciation of the evidence presented at the delinquency hearing for that of the fact finder. View "In the interest of C.D." on Justia Law

In each of two underlying cases, a 14-year-old was convicted of murder and sentenced to a mandatory term of life imprisonment without possibility of parole. The highest courts of Alabama and Arkansas upheld the sentences. The Supreme Court reversed. The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. Children are constitutionally different from adults for sentencing purposes. Their lack of maturity and underdeveloped sense of responsibility lead to recklessness, impulsiveness, and heedless risk-taking. They are more vulnerable to negative influences and lack ability to extricate themselves from horrific, crime-producing settings. A child’s actions are less likely to be evidence of irretrievable depravity. The mandatory penalty schemes at issue prevent the sentencing court from considering youth and from assessing whether the harshest term of imprisonment proportionately punishes a juvenile offender. Life-without-parole sentences share characteristics with death sentences, demanding individualized sentencing. The Court rejected the states’ argument that courts and prosecutors sufficiently consider a juvenile defendant’s age, background and the circumstances of his crime, when deciding whether to try him as an adult. The argument ignores that many states use mandatory transfer systems or lodge the decision in the hands of the prosecutors, rather than courts. View "Miller v. Alabama" on Justia Law