Justia Juvenile Law Opinion Summaries

Terry Break was convicted in 2021 of multiple child sexual abuse offenses, including rape, second-degree sexual assault, and sexual indecency with a child, involving three minor victims. He received six life sentences plus 488 years in prison and $425,000 in fines. His convictions were affirmed on direct appeal. Break then filed a Rule 37 petition for postconviction relief, claiming ineffective assistance of counsel on several grounds.The Boone County Circuit Court denied Break's petition. The court found that the State had provided sufficient evidence of "sexual gratification or desire" for the offenses, and thus, trial counsel was not ineffective for failing to challenge this element. The court also found that the prosecutor's comment during closing arguments, referring to Break as a "proven liar," was based on Break's own admissions and was not improper. Additionally, the court determined that the prosecutor's opening statement did not shift the burden of proof, as it referred to Break's demeanor during a recorded interview rather than his silence at trial. Lastly, the court acknowledged that the prosecutor's biblical reference during closing arguments was improper but concluded that Break failed to show that trial counsel's failure to object constituted ineffective assistance.The Arkansas Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that Break failed to demonstrate that his trial counsel's performance was deficient or that any alleged deficiencies prejudiced the outcome of his trial. The court emphasized that Break did not provide sufficient evidence to support his claims of ineffective assistance and that the decisions made by his trial counsel fell within the range of reasonable professional judgment. View "BREAK v. STATE OF ARKANSAS" on Justia Law

A 16-year-old high school student was convicted of driving under the influence (DUI) of cannabis following a bench trial in the circuit court of Lake County, Illinois. The student was also convicted of improper lane usage, possession of cannabis, and reckless conduct under local ordinances. The incident occurred during a driver's education class, where the instructor noticed erratic driving behavior and reported it to school officials. A subsequent search revealed a marijuana cigarette, and field sobriety tests conducted by a school resource officer and later at the police station indicated impairment.The student appealed to the Appellate Court, Second District, arguing that the Village of Lincolnshire improperly prosecuted him without providing proof of written permission from the State's Attorney, as required by the Illinois Vehicle Code. The student also contended that the evidence was insufficient to prove DUI beyond a reasonable doubt. The appellate court affirmed the conviction, finding no requirement for the Village to submit proof of its authority to prosecute into the trial record and determining that the evidence was sufficient to support the conviction.The Illinois Supreme Court reviewed the case, focusing on whether the Village needed to establish its written permission to prosecute in the trial record and whether the evidence was sufficient to prove the student was under the influence to a degree that rendered him incapable of driving safely. The court held that the statute did not require the Village to submit its written permission into the record and that the failure to do so did not constitute plain error. Additionally, the court found that the evidence, including testimony and field sobriety tests, supported the conviction beyond a reasonable doubt. The Illinois Supreme Court affirmed the appellate court's judgment, upholding the student's conviction. View "Village of Lincolnshire v. Olvera" on Justia Law

Jesse Taylor, Jr. was charged with murder and aggravated assault after his case was transferred from juvenile court to district court in October 2022. In August 2023, a seven-day jury trial was held, and Taylor was found guilty of both charges. He was sentenced to life in prison with the possibility of parole for the murder charge and a concurrent five-year sentence for the aggravated assault charge.Taylor appealed the judgment, raising three issues: the jury's verdict was not unanimous, the district court abused its discretion by denying the defense the ability to properly cross-examine a State's witness, and the court imposed an illegal sentence. The North Dakota Supreme Court reviewed the case. The court found that the jury's verdict was unanimous, as confirmed by the district court on multiple occasions, including a hearing held after the case was remanded. The court also determined that Taylor failed to preserve the issues regarding the evidentiary rulings for appeal, as he did not make an offer of proof or inform the district court of the desired actions or objections.Regarding the sentence, the court noted that Taylor was sentenced to life in prison with the possibility of parole, requiring a determination of his life expectancy. The district court used the age of 15 to determine Taylor's life expectancy, as there was no exact calculated life expectancy for the age of 18 in the mortality table. The North Dakota Supreme Court concluded that the district court acted within the limits of the statute and did not rely on any impermissible factors in determining the sentence.The North Dakota Supreme Court affirmed the judgment, upholding Taylor's conviction and sentence. View "State v. Taylor" on Justia Law

McKinley Kelly, at sixteen, was convicted of murdering three young adults. The trial court vacated one conviction and sentenced him to 110 years in prison. Kelly's appeals and petitions for post-conviction relief were unsuccessful. The Court of Appeals allowed him to file a successive petition for post-conviction relief, focusing on new scientific understandings of adolescent brain development, arguing for a resentencing or a more lenient sentence.The Lake Superior Court denied Kelly's petition, and the Court of Appeals affirmed. Kelly then appealed to the Indiana Supreme Court, which granted transfer to address procedural and substantive issues related to juvenile sentencing. The Indiana Supreme Court affirmed the post-conviction court's decision, concluding that the post-conviction court appropriately allowed Kelly to amend his successive petition without requiring appellate screening.The Indiana Supreme Court held that the state and federal constitutional provisions cited by Kelly did not mandate a more lenient sentence. The court found that Kelly's sentence was not inappropriate given the nature of his offenses and his character. The court emphasized that the legislature had recently amended the sentence modification statute to allow juvenile offenders to have their sentences reexamined after twenty years, providing an opportunity for review based on rehabilitative progress.The court concluded that Kelly's new evidence on adolescent brain development was cumulative and unlikely to produce a different result. The court also rejected Kelly's claims under the Indiana Constitution, finding that his sentence did not violate provisions related to cruel and unusual punishment, proportionality, reformation, unnecessary rigor, or equal protection. Similarly, the court found no violation of the Eighth or Fourteenth Amendments of the U.S. Constitution. Finally, the court declined to revise Kelly's sentence under Appellate Rule 7(B), finding it appropriate in light of the nature of his offenses and his character. View "Kelly v. State of Indiana" on Justia Law

In October 2019, Khrysta Turk reported to the Kalispell Police Department that her stepson, L.S., then 13 years old, had inappropriately touched her four-year-old daughter, E.T. L.S. admitted to the inappropriate touching during a police interview. Following the report, L.S.'s mother placed him in various residential treatment facilities for a total of 728 days. The investigation concluded in December 2019, and the matter was referred to the Eleventh Judicial District Court Office of Youth Services in January 2020. The Youth Court decided to monitor L.S.'s treatment informally without initiating formal proceedings.The State filed a formal petition on January 3, 2022, alleging that L.S. committed acts consistent with felony sexual assault. L.S. was appointed counsel, and the District Court set a trial date. L.S. moved for a continuance due to a discovery violation by the State, which delayed the trial. L.S. also filed motions to dismiss for lack of a speedy trial and for the discovery violation. The District Court denied both motions, noting that the case was atypical due to L.S.'s mother's proactive placement in treatment facilities. The trial was rescheduled multiple times, and L.S. eventually admitted to the allegations while reserving the right to appeal the denial of his motions.The Montana Supreme Court reviewed the case and conducted a speedy trial analysis. The Court determined that the delay of 329 days from the filing of the petition to L.S.'s admission was not extraordinary given the serious nature of the allegations. The Court found that the delays were either institutional or due to L.S.'s request for a continuance. L.S. consistently asserted his right to a speedy trial but failed to demonstrate that the delay prejudiced his defense. The Court concluded that no speedy trial violation occurred and affirmed the District Court's denial of L.S.'s motion to dismiss. View "In re L.S." on Justia Law

In June 2021, the defendant, K.D., stole a car with a one-year-old child inside. She was arrested shortly after and found with the stolen items. K.D. admitted to taking the car and knowing the child was inside. She was charged with kidnapping, child abduction, and vehicle theft. K.D.'s defense counsel raised doubts about her competency, leading to evaluations that diagnosed her with a moderate intellectual disability. She was found incompetent to stand trial and was committed to the Porterville Developmental Center for treatment. After being declared competent in August 2022, K.D. requested developmental disability diversion.The Mendocino County Superior Court initially denied K.D.'s request for diversion, citing her lack of ties to the community, her criminal history, and concerns about her ability to comply with diversion requirements. The court also noted that K.D. had never received services from the regional center and had a history of probation violations. Despite acknowledging her developmental disability, the court concluded that her disability was not related to the charged offense and that she would not benefit from diversion.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court found that the trial court had abused its discretion by not properly considering the relationship between K.D.'s developmental disability and the charged offense. The appellate court noted that the trial court failed to ensure that the regional center provided a proper report and diversion plan tailored to K.D.'s needs. The appellate court conditionally reversed the judgment and remanded the case for a new diversion eligibility hearing, instructing the trial court to comply with statutory requirements and consider whether K.D. would benefit from diversion. If K.D. satisfactorily completes diversion, the charges should be dismissed; otherwise, her conviction should be reinstated. View "People v. K.D." on Justia Law

Jonathan Eluterio Martinez-Garcia, a juvenile offender, attacked his 11th-grade English teacher and subsequently pleaded guilty to attempted murder, attempted sexual assault, and battery with the use of a deadly weapon resulting in substantial bodily harm. The district court sentenced him to two consecutive prison terms of 8 to 20 years and a concurrent term of 6 to 15 years, resulting in an aggregate sentence of 40 years with parole eligibility after 16 years. Martinez-Garcia moved to reconsider the sentence, arguing it was illegal and that he was entitled to parole eligibility after 15 years under NRS 213.12135(1)(a). The district court treated the motion as one to correct an illegal sentence and denied it.Martinez-Garcia appealed the district court's decision, contending that his sentence should reflect parole eligibility after 15 years as mandated by NRS 213.12135(1)(a) for juvenile nonhomicide offenders. He argued that the sentence imposed was illegal because it provided for parole eligibility after 16 years, contrary to the statute. The State argued that the sentence complied with the statutes governing the offenses to which Martinez-Garcia pleaded guilty.The Supreme Court of Nevada reviewed the case and held that NRS 213.12135(1)(a) provides for parole eligibility for juvenile nonhomicide offenders after 15 years by operation of law, without requiring resentencing or amendment of the judgment of conviction. The court concluded that the statute does not render a sentence illegal if it otherwise conforms to the sentencing statutes for the offenses committed. Therefore, the court affirmed the district court's order denying Martinez-Garcia's motion to correct an illegal sentence, acknowledging that he will be eligible for parole after 15 years despite the longer parole-eligibility period stated in the judgment of conviction. View "GARCIA VS. STATE" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law

Ramiro Munoz, a member of a criminal street gang, was convicted in 2008 of first-degree murder and shooting at an occupied motor vehicle, with firearm and gang allegations found true. Munoz, who was 15 years old at the time of the crime, was sentenced to 50 years to life in prison. In 2023, Munoz filed a petition for recall and resentencing under Penal Code section 1170, subdivision (d)(1), arguing that his sentence was the functional equivalent of life without the possibility of parole, making him eligible for relief under the statute.The Superior Court of Los Angeles County denied Munoz's petition, stating that he would be eligible for parole under section 3051 in 2029, when he would be 39 years old. Munoz appealed the decision, and the case was reviewed by the Court of Appeal of the State of California, Second Appellate District, Division Seven.The Court of Appeal affirmed the superior court's decision, holding that Munoz's sentence of 50 years to life is not the functional equivalent of life without the possibility of parole. The court concluded that section 1170, subdivision (d)(1), applies only to juvenile offenders explicitly sentenced to life without the possibility of parole and does not extend to those with lengthy sentences that may be considered de facto life without parole. The court also noted that Munoz would have a realistic opportunity to obtain release from prison during his expected lifetime, distinguishing his case from others with significantly longer sentences. View "People v. Munoz" on Justia Law