Justia Juvenile Law Opinion Summaries

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

This matter involved two cases, one involving two youths who appeared in youth court for detention hearings and one involving an adult who pled guilty to driving under the influence in justice court. After appearing in district court, the youths filed motions to substitute district court judge, and the court denied the motions as untimely. After the adult pled guilty in justice court, she appealed only the justice court's denial of her pretrial suppression motion, which the district court denied as untimely. The Supreme Court granted a petition for writ of supervisory control for the youths and denied it for the adult, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court correctly denied the adult's motion for substitution of district court judge, as no right exists under Mont. Code Ann. 3-1-804 to substitute a district judge in an appeal of a specific pre-trial legal ruling from justice court. View "Bledsoe v. Dist. Court" on Justia Law

Appellant N.D. was a juvenile when he was adjudicated delinquent for commission of aggravated robbery and possession of a weapon. After N.D. escaped from the detention center, the State filed a felony information charging N.D. as an adult with capital murder, escape in the first degree, aggravated robbery, theft of property, and second-degree battery. After the Supreme Court reversed the criminal court's denial of N.D.'s motion to transfer his case to the juvenile court, the criminal court transferred N.D.'s case to juvenile court. The juvenile court subsequently entered a decision that N.D. be designated for extended juvenile jurisdiction (EJJ). N.D. appealed, asserting that the criminal court already declined to make such a designation, and because the Supreme Court did not reverse that refusal in N.D.'s first appeal, the issue was decided by law of the case. The Supreme Court affirmed, holding that the Court did not previously reach a decision or provide direction to the criminal court with respect to EJJ designation, nor did the criminal court make a decision regarding EJJ designation, and so the law-of-the case doctrine did not bar the juvenile court from granting the State's motion for an EJJ designation. View "N.D. v. State" on Justia Law