Justia Juvenile Law Opinion Summaries

The issue this case presented for the Georgia Supreme Court's review centered on whether a child charged with delinquency based on an alleged violation of Georgia’s Criminal Code could assert an affirmative defense of insanity or delusional compulsion, under OCGA §sections 16-3-2 or 16-3-3, in a juvenile-court proceeding. The Georgia Supreme Court found that the Juvenile Code did not expressly state whether affirmative defenses provided for in the Criminal Code were available in juvenile court. Based on the Juvenile Code’s text and structure, however, the Court concluded that insanity and delusional-compulsion defenses were available in most delinquency proceedings, specifically holding that in a delinquency proceeding, a child could assert an insanity or delusional-compulsion defense under OCGA sections 16-3-2 or 16-3-3 when the child’s delinquency charge is based on an allegation that the child committed “[a]n act . . . designated a crime by the laws of this state.” Because the juvenile court erred in concluding that a child could never raise an insanity or delusional-compulsion defense in a delinquency proceeding, the Supreme Court vacated the court’s order denying the motion of T.B. which sought a forensic psychological evaluation for purposes of raising a defense under OCGA 16-3-2 or 16-3-3. The case was remanded for further proceedings. View "In the Interest of T.B." on Justia Law

M.Y.G. was 15 years old when he stole two cars. The State charged him with two counts of theft of a motor vehicle. M.Y.G. moved for and was granted a deferred disposition, but he objected to providing a DNA sample. The trial court ordered M.Y.G. to submit a DNA sample but stayed collection pending appeal. The Court of Appeals affirmed the trial court, upholding the DNA collection. I.A.S. was 17 years old and under the influence of alcohol when he stole a truck, crashed it into a tree, and ran from the scene. The State charged him with one count of second degree burglary, theft of a motor vehicle, second degree theft, driving under the influence, and failure to remain at the scene of an accident. I.A.S. moved for and was granted a deferred disposition. He too objected to providing a DNA sample, but the court ordered him to submit one, staying collection pending his appeal. The Court of Appeal again affirmed the trial court, requiring I.A.S. to give a DNA sample. I.A.S. and M.Y.G. appealed, presenting the question of whether a juvenile was “convicted” when they enter into a deferred disposition. The Washington Supreme Court held that a juvenile is “convicted” when they enter into a deferred disposition. However, the Court held that the juvenile offenses committed by the petitioners in this case did not trigger the DNA collection statute. Therefore, the Supreme Court affirmed the Court of Appeals in part and reversed in part. The orders requiring a DNA sample from M.Y.G. and I.A.S were vacated. View "Washington v. M.Y.G." on Justia Law

Plaintiffs in this action are minors who resided in San Diego County. Plaintiffs sued the County and County social workers for allegedly violating their Fourth Amendment rights by interviewing them without a court order or parental consent during the course of a child-abuse investigation. During that investigation, the County created and maintained files related to the alleged child abuse. Attorneys defending the County reviewed the child-abuse investigation file without first obtaining a court order. Plaintiffs then brought an action, alleging that the attorneys who accessed the file violated their right to privacy.The Ninth Circuit affirmed the district court’s dismissal of the action. The court held that, contrary to Plaintiffs’ argument, Gonzalez v. Spencer, 336 F.3d 832 (9th Cir. 2003) (per curiam), abrogated on other grounds by Filarsky v. Delia, 566 U.S. 377 (2012) does not stand for the proposition that a right to privacy necessarily attaches to the type of records at issue here. Further, even if Plaintiffs were entitled to informational privacy, the balancing test recognized in Seaton v. Mayberg, 610 F.3d 530 (9th Cir. 2010), showed the County’s interest in defending this litigation outweighed Plaintiffs’ asserted privacy interest. Even assuming that the social workers’ records comprised sensitive medical and psychological records, there was no constitutional violation because the County’s need to access the records was high. Plaintiffs initiated that need, and the professional obligations that lawyers owe their clients minimized the risk of misuse, harassment, or embarrassment. Thus, the district court properly dismissed Plaintiffs’ Monell claim. View "A.C. V. ERICA CORTEZ" on Justia Law

The issue presented by this appeal was whether youthful offenders who are statutorily ineligible for early parole consideration were nevertheless entitled to a "Franklin" proceeding to preserve evidence for their eventual parole hearing. During his early 20’s, appellant was involved in three separate criminal incidents. s a result of those incidents, appellant was convicted of kidnapping for robbery and multiple counts of robbery, burglary, false imprisonment and illegal gun possession. He was also found to have personally used a firearm during the offenses and suffered a prior strike conviction. The trial court sentenced him to 59 years to life in prison under the “Three Strikes” law. In 2020, appellant requested a Franklin proceeding to present mitigation evidence in anticipation of his youth offender parole hearing (YOPH). However, the trial court correctly determined appellant was not eligible for a YOPH because he was sentenced under the Three Strikes law. Therefore, it denied his request for a Franklin proceeding. Appellant admitted he was statutorily ineligible for a YOPH because he was sentenced under the Three Strikes law. However, he contended he is entitled to a YOPH – and a concomitant Franklin proceeding – as a matter of equal protection. Although the Court of Appeal rejected appellant’s equal protection argument, both parties concluded he was entitled to a Franklin proceeding under the standard rules applicable to all parole hearings. The trial court's judgment was reversed and the case remanded for such a proceeding. View "California v. Delgado" on Justia Law

Kevonta Daniels was convicted by jury of felony murder in connection with the shooting death of Kenneth Moore; the aggravated assaults of Jai Williams, Jamal Williams, and James Williams; the theft of vehicles belonging to Jamal Williams, Marcus Jones, and Alvin Walker; and other offenses. Following the denial of his motion for new trial, Daniels argued on appeal that the trial court erred by admitting statements he made to the police into evidence at trial. Daniels, who was 14 years old at the time of the crimes and when he was interviewed by the police, specifically argued the State failed to prove that he knowingly and voluntarily waived his constitutional rights before speaking with the police and that his statements should also have been excluded because the police failed to comply with provisions of the Juvenile Code relating to custody of juvenile arrestees. Finding no reversible error, the Georgia Supreme Court affirmed. View "Daniels v. Georgia" on Justia Law

In 2009, when he was seventeen-and-a-half years old, appellant Michael Felder was playing in a pick-up basketball game with Andrew Williams at an outdoor court in Philadelphia. The pair were matched against brothers Jarrett and Malcolm Green. Appellant’s style of play became aggressive; an argument ensued after Williams refused to hand the ball over to the Greens. Appellant walked to the sideline and removed a .380 semiautomatic handgun from his gym bag, and shot Malcolm in the head before shooting Jarrett in the stomach and leg. A jury convicted appellant of first-degree murder and aggravated assault. Pursuant to the then-applicable mandatory sentence for first-degree murder, which also applied to juveniles, appellant was sentenced to life imprisonment without the possibility of parole. The Superior Court vacated appellant’s judgment of sentence two years later; by then, Miller v. Alabama, 567 U.S. 460 (2012) and Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (“Batts I”) had been decided. Since appellant’s judgment of sentence was not yet final, the Superior Court determined he was entitled to the benefit of those rulings and to consideration of the Miller factors before being resentenced, and remanded the case for such proceedings. Upon remand, the court imposed a discretionary 50-years-to-life sentence for appellant’s first-degree murder conviction. On appeal to the Superior Court, appellant challenged the legality of his sentence, arguing “a 50-year minimum sentence is a de facto life sentence.” The Superior Court found that although the sentence precluded appellant from seeking parole until he was 68 years old, it was constitutional because it “was the result of an individualized and discretionary sentencing hearing[.]” The Pennsylvania Supreme Court granted discretionary review limited to whether appellant's sentence was indeed a de facto life sentence requiring the sentencing court under Commonwealth v. Batts, 163 A.3d 410 (Pa. 2017) (“Batts II”), "[to] first find permanent incorrigibility, irreparable corruption or irretrievable depravity beyond a reasonable doubt." The Supreme Court determined Jones v. Mississippi, 141 S.Ct. 1307 (2021) "abrogates our foundational understanding in Batts II." So long as the sentence imposed is discretionary and takes into account the offender’s youth, even if it amounts to a de facto life sentence, Miller is not violated. "Because the sentencing court in the present case followed this procedure, we affirm." View "Pennsylvania v. Felder" on Justia Law

Defendant-appellant Elijah Hall was convicted by jury of six counts of robbery committed for the benefit of a criminal street gang and one count of active gang participation (all committed when he was 15 years old), and he received a sentence of 65 years to life in state prison. Hall appealed, and while his appeal was pending, Proposition 57 raised the minimum age a minor could be tried as an adult in criminal court from 14 to 16. Following the procedure approved in California v. Superior Court (Lara) 4 Cal.5th 299 (2018), the trial judge recalled Hall’s sentence and transferred his case to juvenile court, where the judge “treat[ed the] convictions as juvenile adjudications” and held a hearing to impose an appropriate disposition. After Hall was transferred to the Department of Juvenile Justice, he informed the Court of Appeal he wished to proceed with his appeal, which was reinstated as an appeal of a judgment in a juvenile criminal proceeding. Hall raised two challenges to the criminal trial on which his juvenile adjudications were based: (1) the trial judge violated his due process rights by instructing the jury with CALCRIM No. 315, which covered eyewitness identification evidence and tells the jury to consider, among other factors, the witness’s level of certainty when making the identification; and (2) Assembly Bill No. 333 (2021–2022 Reg. Sess.) required reversal of the true findings on the substantive gang offense and enhancements because the new law increased the proof requirements under the gang statute (Pen. Code 186.22). The Court of Appeal rejected Defendant's first argument under California v. Lemcke, 11 Cal.5th 644 (2021), in which the Supreme Court held that CALCRIM No. 315’s certainty factor did not violate due process. The Court agreed with Defendant's second argument, and remanded the case to give the State an opportunity to retry the substantive charge and enhancement allegations under Assembly Bill 333’s new requirements in a juvenile criminal proceeding, and impose a new disposition in Hall’s case - either at the conclusion of retrial or upon the State's election not to retry him. Judgment was affirmed in all other respects. View "California v. Hall" on Justia Law

In winter 1996, defendant Samuel Ryan (then aged 23) robbed a Bridgeton, New Jersey gas station at gunpoint, stealing $100 and shooting a store clerk in the process. The offense resulted in defendant’s third first-degree robbery conviction, and he was sentenced to life in prison without parole pursuant to the Persistent Offender Accountability Act, known as the “Three Strikes Law.” In this appeal, defendant contended the Three Strikes Law violated the prohibition against cruel and unusual punishment contained in the Eighth Amendment of the United States Constitution and Article I, Paragraph 12 of the New Jersey Constitution. He alleged that, by allowing courts to count crimes committed while under the age of eighteen as predicate offenses in sentencing defendants to mandatory life without parole, the Three Strikes Law ignored the constitutional constraints embodied in Miller v. Alabama, 567 U.S. 460 (2012), and New Jersey v. Zuber, 227 N.J. 422 (2017), which prohibited imposition of mandatory life-without-parole sentences or their functional equivalent on juvenile offenders. The New Jersey Supreme Court found that because defendant committed his third offense and received an enhanced sentence of life without parole as an adult, this appeal did not implicate Miller or Zuber. Accordingly, defendant’s sentence was affirmed and the Court reaffirmed the constitutionality of the Three Strikes Law. View "New Jersey v. Ryan" on Justia Law

The Supreme Court vacated the judgment of the circuit court finding that Juvenile committed acts that would constituted first-degree statutory sodomy if committed by an adult, holding that the circuit court erroneously declared and applied the law in admitting two-way video testimony, in violation of Juvenile's right to confrontation.Prior to his adjudication hearing, Juvenile filed an objection to a virtual adjudication and request to appear in person, arguing that he had a constitutional and statutory right to face-to-face confrontation of witnesses against him. The objection was overruled, and the court held the hearing in a "hybrid" format that utilized videoconferencing technology due to the COVID-19 pandemic. After the hearing, the circuit court sustained the allegation of first-degree statutory sodomy beyond a reasonable doubt. The Supreme Court vacated the judgment, holding that the circuit court's general statements concerning COVID-19 did not satisfy the requisite standard for admitting two-way video testimony, in violation of Juvenile's confrontation rights. View "In re C.A.R.A." on Justia Law

The Supreme Court vacated the judgment of the circuit court finding that J.A.T. committed acts that would constitute first-degree assault and armed criminal action if committed by an adult, holding that requiring J.A.T. to attend the adjudication hearing via two-way live video violated his constitutional rights to due process and confrontation.While J.A.T. repeatedly asserted his right to be physically present at his adjudication hearing to defend himself, the circuit court required J.A.T. to attend his adjudication hearing via two-way video to limit the exposure of germs during the COVID-19 pandemic. The Supreme Court vacated the circuit court's judgment, holding (1) generalized concerns about the COVID-19 virus may not override a juvenile's due process right to be physically present for his juvenile adjudication hearing at which his guilt or innocence will be determined; and (2) the circuit court erred in requiring J.A.T.'s attendance and participation via two-way video, in violation of J.A.T.'s due process right to be physically present at his adjudication hearing. View "In re J.A.T." on Justia Law