Justia Juvenile Law Opinion Summaries

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute. View "In re M.L.M." on Justia Law

Three juvenile defendants, each of whom was a member of an Indian Tribe and who pleaded true to a charge of aggravated sexual abuse with children, appealed their conditions of probation or supervision requiring registration under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901, et seq. Defendants argued that SORNA's registration requirement contravened the confidentiality provisions of the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031 et seq., and also challenged its constitutionality. The court held that because Congress, in enacting SORNA, intentionally carved out a class of juveniles from the FJDA's confidentiality provisions, and that SORNA's registration requirement was constitutionally sound, the district court's imposition of the sex offender registration conditions was constitutionally sound. View "United States v. Juvenile Male" on Justia Law

A juvenile male appealed the district court's determination that he was an "Indian" under 18 U.S.C. 1153, which provided federal criminal jurisdiction for certain crimes committed by Indians in Indian country. The juvenile claimed that he did not identify as an Indian, and was not socially recognized as Indian by other tribal members. Nonetheless, he was an enrolled tribal member, had received tribal assistance, and had used his membership to obtain tribal benefits. Therefore, because the juvenile was Indian by blood and easily met three of the most important factors used to evaluate tribal recognition laid out in United States v. Bruce, the court held that he was an "Indian" under section 1153 and upheld his conviction. View "United States v. Juvenile Male" on Justia Law

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law

T.M.L. was seventeen when he pled guilty to felony burglary and misdemeanor criminal trespass to vehicles. The youth court entered a dispositional order providing that T.M.L. be placed on probation until he reached age eighteen, after which supervision was to be transferred to the district court and adult probation and parole department. After T.M.L. turned eighteen, the youth court transferred T.M.L.'s matter to district court and transferred T.M.L.'s supervision to adult supervision under the department of corrections. The Supreme Court (1) affirmed the youth court's denial of T.M.L.'s motion to dismiss where the youth court had jurisdiction over T.M.L.; and (2) remanded the matter for the limited purpose of striking the condition that T.M.L. register as a sexual offender as a condition of T.M.L.'s sentence, as the youth court did not have the power to require T.M.L. to register as a sexual offender. View "In re T.M.L." on Justia Law

Anthony F. appealed an order by the Derry District Court that denied his motion to suppress evidence that supported a child delinquency petition against him. The juvenile was stopped by school officials as he was leaving campus one morning in 2008. He refused to return, stating he did not feel well. Assistant principals escorted him back to the school where he was searched. One assistant principal asked the juvenile if he had "anything on [him] that [he] shouldn’t have on school property." The juvenile eventually handed over a small bag of marijuana that he retrieved from inside his sock. Subsequently, a delinquency petition was filed. The juvenile moved to suppress the marijuana evidence, arguing that the search was unconstitutional under the New Hampshire and Federal Constitutions. The State countered that there was no search under the law, but even if a search occurred, it was constitutionally valid. Upon review, the Supreme Court concluded that the facts of this case did not support a finding of reasonable grounds for suspecting that a search of this juvenile would turn up contraband. The assistant principals searched the juvenile because it was school policy to search all students who return to school after leaving an assigned area. The record reveals, however, that the juvenile was leaving the school, not returning. It was school officials who forced his return. The Court held that the search was "suspicionless" and as such, illegal. The Court reversed the decision in this case and remanded the case for further proceedings. View "In re Anthony F. " on Justia Law

Defendant, a 15-year-old, was tried as an adult and convicted of the murder of a 72-year-old and of five first degree burglaries relating to the residences of the victim and two other women. At issue was whether defendant made a postwaiver invocation of his Miranda rights by asking several times to speak to his mother or by making certain other statements while being questioned. The court held that juveniles claiming a postwaiver invocation of their Miranda rights were properly subject to the Davis v. United States standard. Applying that standard, the court concluded that the trial court did not err in finding that defendant's requests to speak to his mother and other statements were not sufficiently clear to require cessation of the interrogation. Accordingly, defendant's confessional statements were properly admitted at trial, and the contrary judgment of the Court of Appeal must be reversed. View "People v. Nelson" on Justia Law

The State filed a delinquency petition alleging that a seventeen-year-old girl had engaged in criminal solicitation to commit murder after she asked a stranger to punch her in the stomach to terminate her pregnancy. The juvenile court (1) held that an assault of a woman by punching her in the stomach was a "procedure" intended to terminate her pregnancy and therefore qualified as an abortion under statute; and (2) dismissed the State's petition against the minor because a woman cannot be held criminally liable for seeking an abortion. The Supreme Court reversed, holding that the solicited assault of a woman to terminate her pregnancy was not a "procedure" as contemplated by statute and therefore did not constitute an abortion. Remanded. View "State v. J.M.S." on Justia Law

The Supreme Court granted a writ application to determine whether a school board had tort liability for expelling a high school student after a fifth-sized bottle of whiskey fell from the student's backpack and broke on the classroom floor. The student claimed he was denied due process in the disciplinary proceedings that resulted in his expulsion. The district court agreed and awarded the student $50,000. Upon review of the trial court record, the Supreme Court found that the student presented no evidence whatsoever of being denied due process at the school board hearing. Finding the student failed to carry his burden of proof to show a denial of due process by the school board, the Court reversed the judgment of the district court. View "Christy v. McCalla" on Justia Law

After a jury trial, Appellant Scott Brockelbank was convicted of aggravated criminal trespass and assault. The Court of Appeals affirmed Appellant's judgment and sentence, holding (1) the evidence was sufficient to disprove Appellant's competing harms defense because there was sufficient evidence for the jury to find that the State disproved at least one of the elements of the defense; and (2) the sentencing court acted within its discretion by permitting the State to introduce information related to Appellant's nonpublic juvenile adjudication during the sentencing proceedings to the limited extent reasonably necessary to respond to and explain information introduced by Appellant related to the same adjudication. View "State v. Brockelbank" on Justia Law