Justia Juvenile Law Opinion Summaries

When he was fifteen years old, E.C. pled guilty to breaking and entering and rape. After E.C. was released from custody and placed under parole supervision, a team of attorneys filed a petition for a writ of habeas corpus on E.C.'s behalf alleging that E.C.'s guilty plea was neither knowing nor voluntary and was unconstitutionally invalid because of ineffective assistance of counsel. Six days after his petition was filed, E.C. was released from parole supervision. The circuit court dismissed the petition, concluding that it had no jurisdiction to consider the petition and that the habeas corpus proceeding was moot. The Supreme Court reversed, holding (1) the circuit court had active jurisdiction over the proceeding because E.C. was detained for purposes of habeas corpus when the petition was filed; and (2) E.C.'s release from probation during the pendency of the habeas corpus proceeding did not automatically render the proceeding moot, as the collateral consequences imposed on E.C. by the convictions he challenged were sufficient to sustain a continued controversy. View "E.C. v. Va. Dep't of Juvenile Justice" on Justia Law

Appellant was charged with complicity to commit assault in the first degree, attempted burglary in the first degree, and tampering with physical evidence in a juvenile proceeding. Appellant was sixteen years old at the time. The district court found there was no probable cause to believe Appellant had used a firearm in the commission of the offenses under Ky. Rev. Stat. 635.020(4) and therefore declined to order transfer of Appellant to circuit court as a youthful offender. The Commonwealth filed a petition for a writ of mandamus, asking the circuit court to order the district court to transfer Appellant as a youth offender. The circuit court granted the writ, and the court of appeals affirmed. The Supreme Court affirmed, holding that the writ of mandamus issued by the circuit court was not an abuse of discretion where (1) a crime committed by complicity can fall under the mandatory transfer provision of section 635.020(4), and complicity to commit an offense involving use of a firearm requires transfer when an offense involving direct use of a firearm would; and (2) the district court erred in finding that a firearm was not used in Appellant's offense. View "K.R. v. Commonwealth" on Justia Law

S.L. was charged with one count of rape in the juvenile division of the circuit court. Before the adjudication hearing, S.L. filed a motion to dismiss for violation of his right to a speedy trial, which the circuit court denied. S.L. then filed another motion to dismiss for lack of a speedy trial, which the circuit court granted. The State appealed. After noting that the State's appeal under these circumstances required the Supreme Court's review for the correct and uniform administration of the criminal law under Ark. R. App. P.-Crim. 3(d) instead of relying on facts unique to the case, the Court dismissed the appeal, as it did not have at issue the correct and uniform administration of justice and, instead, involved the application of the Court's speedy-trial rules to the unique facts of the case. View "State v. S.L." on Justia Law

In this discretionary appeal, the Supreme Court considered whether under Pennsylvania’s Juvenile Act, a juvenile court is required to enter on the record an adjudication of delinquency once it has determined the juvenile committed the acts alleged in the delinquency petition, or whether the court must make an additional finding that the juvenile is in need of treatment, supervision, or rehabilitation, prior to entering an adjudication of delinquency. In 2007, the Commonwealth filed a delinquency petition against M.W. alleging that he and another youth robbed an individual who had just left a local bar. At an adjudicatory hearing, the juvenile court found that M.W. committed robbery, conspiracy, and related charges. Later that same day, M.W. was adjudicated delinquent by another juvenile court judge on a separate delinquency theft petition, and M.W. was committed for treatment, rehabilitation, and supervision. After a hearing on the first petition, the trial court discharged the delinquency petition stemming from the robbery offense, noting that M.W. "will be adjudicated on the [theft] petition. He will still receive treatment and supervision." The Commonwealth filed a motion for reconsideration, which was denied. The Commonwealth then appealed to the Superior Court, where it argued that the juvenile court abused its discretion and violated the requirements of the Juvenile Act by failing to adjudicate M.W. delinquent once it found that M.W. had committed the acts alleged in the original delinquency petition. Upon review, the Court held that the Juvenile Act requires a juvenile court to find both: (1) that the juvenile has committed a delinquent act; and (2) that the juvenile is in need of treatment, supervision, or rehabilitation, before the juvenile court may enter an adjudication of delinquency. In this case, the Court reversed the decision of the Superior Court. View "Pennsylvania v. In the Interest of M.W." on Justia Law

Petitioner was convicted of first degree murder when she was 16 years old for her part in the murder of her boyfriend. Petitioner appealed the district court's dismissal of three claims in her federal habeas petition as untimely under the one-year statute of limitations set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(d)(1). Because the court applied the AEDPA statute of limitations on a claim-by-claim basis, and because petitioner's three claims challenging a state administrative agency's order were filed nearly 18 months after the statute of limitations expired, the court affirmed the district court's dismissal. View "Mardesich v. Cate, et al." on Justia Law

This case arose from a dependency-neglect proceeding. After a permanency-planning hearing was set, the circuit court discovered that the Department of Human Services (DHS) had failed to draft and put into place a case plan. The court then ordered that, as the case worker had forty-one cases on her caseload and fifty juveniles in fostercare, DHS should rectify the issue in five days. DHS subsequently filed a petition for a writ of certiorari, asserting that the circuit court exceeded its jurisdiction and violated the separation-of-powers doctrine by issuing an order that DHS alleged invaded the discretionary functions of the executive branch. The Supreme Court denied the writ, holding that the circuit court was within its jurisdiction to act to protect the integrity of the proceedings and to safeguard the rights of the litigants before it when it ordered DHS to correct problems that were preventing work and services. View "Ark. Dep't of Human Servs. v. Shelby" on Justia Law

Defendant appealed from a Family Court sentencing order initially entered when he was a juvenile where he robbed a woman with a BB gun. Defendant contended that the Family Court did not have the authority to sentence him, at the outset, to twelve months of adult probation following his juvenile commitment. Because the statute the Family Court relied upon affirmatively provided only two circumstances, not present in this case, where the Family Court could sentence a juvenile to adult probation, the court found that the General Assembly intended to limit the authority of the Family Court to impose adult consequences on the juvenile. Accordingly, the court reversed and remanded for a correction of the sentence order. View "Brown v. State" on Justia Law

Defendant was indicted in superior court for armed robbery and other offenses even though he was 16 years old at the time of the alleged crimes. Defendant moved to transfer the case to juvenile court. Although the superior court found that no money was actually physically removed from the cash register, the trial court denied the motion to transfer, concluding that a taking and thus an armed robbery had occurred. The Court of Appeals affirmed. The court held that the Court of Appeals correctly affirmed the superior court's denial of the motion to transfer where the single act of pulling a cash drawer out from the register constituted the requisite change of location. View "Gutierrez, et al. v. Holder, Jr." on Justia Law

In this juvenile delinquency case, the prosecution filed an interlocutory appeal seeking the Supreme Court's review of a magistrate's order suppressing certain statements made by the juvenile during a police interrogation. Because the magistrate's suppression order was never reviewed and adopted (with or without modification) by the district court before the appeal was filed, the Supreme Court lacked appellate jurisdiction, and accordingly dismissed the appeal. View "Colorado v. S.X.G." on Justia Law

Defendant, a juvenile, was charged in a complaint with being a delinquent child for breaking and entering a motor vehicle in the nighttime, with the intent to commit a felony. At issue was whether G.L.c. 119, section 58, empowered a Juvenile Court judge to continue a delinquency case without a finding and place the juvenile under the supervision of the probation department, notwithstanding a jury's prior verdict of delinquency. Based on the text of the statute, its placement within the broader statutory scheme, and the underlying philosophy of the juvenile justice system, the court concluded that it did. Accordingly, the case was remanded to the county court, where an order shall enter affirming the Juvenile Court judge's order. View "Commonwealth v. Magnus M." on Justia Law