Justia Juvenile Law Opinion Summaries

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

Defendant violated several terms of the youthful offender agreement and, at the subsequent sentencing proceeding, Supreme Court imposed a determinate prison sentence of three and one-half years plus five years of post-release supervision. On appeal, defendant contended that reversal was required under People v Catu. The court held that, having elected to advise defendant of the consequences that might flow from the violation of the youthful offender agreement, Supreme Court referenced only a prison term, omitting any mention of the possibility of post-release supervision, thereby giving defendant an inaccurate impression concerning the sentencing options. Accordingly, the court concluded that reversal and vacatur of the plea was appropriate. View "People v McAlpin" on Justia Law

Twelve-year old Frances G. told a law enforcement officer that she threw a rock or brick against the windshield of a vehicle and carved something into the side of the vehicle. After a trial before a justice of the family court, Frances was adjudicated to be wayward. The Supreme Court affirmed, holding (1) the trial justice was not clearly wrong when she allowed the vehicle's owner to testify about what her daughter told her she saw Frances do to the car because the statement qualified as an "excited utterance" under R.I. R. Evid. 803(2); and (2) Frances knowingly and voluntarily waived her Miranda rights before speaking to the law enforcement officer, and therefore, the trial justice did not err in admitting the statement into evidence. View "In re Frances G." on Justia Law

Defendant left his seriously dysfunctional home at age 14 and began living with an adult who sold him to older men for sex. They were joined by two young girls. The four engaged in group sex. Defendant was convicted of first degree sexual assault of a child, based on oral sex performed on defendant (then age 15) by a 12-year-old, and sentenced to 40 years. Wisconsin state courts rejected his claims of ineffective assistance of counsel. The district court denied a petition for habeas corpus. The Seventh Circuit affirmed, rejecting an argument that defendant received constitutionally ineffective assistance from his trial counsel, who failed to request a jury instruction including the statutory words defining the charged offense: "either by the defendant or upon the defendant's instruction." The state court determination that any error was not prejudicial was not unreasonable, in light of the circumstances surrounding the incident and the possibility that the statutory language court be read as covering situations in which a defendant allowed the sexual conduct. The court noted that it was not unmindful of the circumstances that led defendant to the situation and that it trusted the parole board to take those circumstances into account.View "Steffes v. Thurmer" on Justia Law

Defendants the Colbert County Board of Education ("the Board"); and the individual members of the Board and members of the Colbert County High School appealed a trial court's judgment that granted Plaintiff Felecia James's motion for a preliminary injunction. On or about May 21, 2010, an incident occurred at Colbert County High School (CCHS) involving J.H., Plaintiff's minor child, and another minor enrolled in CCHS. The details of the incident were disputed, but they led the assistant principal of the school to suspend both students for three days for allegedly fighting on school property during school hours. Plaintiff appeared before the Board to discuss the situation. The Board apparently took no action, and Plaintiff "individually and as mother and guardian of J.H." sued the Board and the individually named defendants asserting state-law and federal-law claims She also filed a motion for a temporary restraining order, a preliminary injunction, and a permanent injunction. Upon review, the Supreme Court found that the Board members in their official capacities were immune from the state-law claims filed against them insofar as those claims sought monetary damages. As such, the trial court lacked subject-matter jurisdiction over those state-law claims against the officials in their official capacities. However, the Board members were not immune from Plaintiff's state-law claims insofar as she sought injunctive relief based upon the Board members' alleged fraud, bad faith, or actions that were beyond the Board members' authority or that were taken under a mistaken interpretation of law. The Court noted that the Board and its members were not immune from the federal-law claims filed against them. Based on the foregoing, insofar as the Board appealed the preliminary injunction against it based upon the state-law claims filed by Plaintiff, the Supreme Court dismissed their appeal for lack of subject-matter jurisdiction. Because the Court reversed the preliminary injunction, the Court declined to order the trial court to vacate the preliminary injunction entered against the Board insofar as it was based on those claims. View "Colbert Cty. Bd. of Edu. v. James" on Justia Law