Justia Juvenile Law Opinion Summaries

A father was accused of sexually abusing and assaulting his 11-year-old daughter over the course of a single day. The daughter testified to three separate incidents: in the family’s toy room, the father touched her chest through her clothes and showed her a pornographic video; in the school room, he told her they would have vaginal sex that night, described the pain she would experience, touched her vagina through her clothes, and made her touch his exposed penis; later, while driving her to a store, he touched her again, showed more pornographic videos, and, after stopping on a dirt road, moved her onto his lap, sucked on her chest, touched her vagina, kissed her, and asked if she was sure about having sex.A jury in the United States District Court for the Northern District of Oklahoma found the father guilty of abusive sexual contact with a minor under 12 and assault with intent to commit aggravated sexual abuse. After the verdict, the district court entered a judgment of acquittal on the assault charge, reasoning that the evidence was insufficient because the father had said the sex would occur later that night, not immediately. The government moved for reconsideration, and the district court reinstated the conviction, concluding that a reasonable jury could have found both assault and the required intent.The United States Court of Appeals for the Tenth Circuit reviewed three issues: whether the district court plainly erred by not instructing the jury to agree on a specific incident of sexual contact, whether the district court could reinstate the assault conviction after acquittal, and whether sufficient evidence supported the assault conviction. The court held that the omission of a specific unanimity instruction did not affect the defendant’s substantial rights, that the district court could correct its mistaken acquittal without violating the Double Jeopardy Clause, and that sufficient evidence supported the assault conviction. The convictions were affirmed. View "United States v. Roark" on Justia Law

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

In December 2020, Gavin Smith's grandfather discovered Smith's mother, stepfather, and two younger brothers shot to death in their home. Smith, who was sixteen at the time, was later found at his girlfriend's grandmother's house and arrested. Smith's girlfriend, Rebecca Walker, was also charged but entered a plea agreement to testify against Smith in exchange for a reduced sentence.The Circuit Court of Kanawha County transferred Smith from juvenile to adult criminal jurisdiction. A grand jury indicted him on four counts of first-degree murder and four counts of using a firearm during a felony. During the trial, Walker testified about her plea deal and the events of the murders. Smith's counsel cross-examined her about the life sentence she avoided, leading to a court instruction clarifying that Smith would be eligible for parole after fifteen years due to his age at the time of the crime.The jury convicted Smith of three counts of first-degree murder, one count of second-degree murder, and one count of using a firearm during a felony. The court sentenced him to three life terms with mercy plus fifty years, all to run consecutively.The Supreme Court of Appeals of West Virginia reviewed the case. Smith argued that the circuit court erred by informing the jury about his parole eligibility, which prejudiced the jury. The Supreme Court agreed, finding that the circuit court's instruction on parole eligibility was improper and prejudicial. The court held that outside the context of cases involving a recommendation of mercy, it is improper to inform the jury about sentencing possibilities. Consequently, the Supreme Court vacated Smith's convictions and the circuit court's sentencing order, remanding the case for a new trial. View "State v. Smith" on Justia Law

A 15-year-old male was charged with a Class II felony for allegedly sexually assaulting a 14-year-old female at a high school in Omaha, Nebraska. The incident was reported by the victim, L.S., who stated that the assault occurred within the school premises. Video footage and interviews with the involved parties, including the accused, Jeremiah T., and a witness, G.G., were part of the evidence. L.S. claimed that Jeremiah forcibly assaulted her despite her resistance, while Jeremiah contended that the encounter was consensual. G.G.'s involvement as a lookout was also scrutinized.The district court overruled Jeremiah's motion to transfer the case to juvenile court, citing concerns about public safety and the severity of the offense. The court found that the nature of the crime and the degree of violence involved suggested that Jeremiah might need supervision beyond the age of 19, which the juvenile court could not provide. The court also noted that while Jeremiah was amenable to treatment, the timeline for effective rehabilitation within the juvenile system was uncertain.The Nebraska Court of Appeals reversed the district court's decision, arguing that the lower court abused its discretion. The appellate court emphasized that the evidence favored Jeremiah's rehabilitation within the juvenile system and that the State did not sufficiently prove a sound basis for retaining the case in adult court. The Court of Appeals highlighted the availability of appropriate services in the juvenile system and questioned the district court's interpretation of the evidence.Upon further review, the Nebraska Supreme Court found that the Court of Appeals had improperly reweighed the evidence and failed to apply the correct standard of review. The Supreme Court held that the district court did not abuse its discretion in retaining the case in adult court, as its decision was supported by appropriate evidence and considerations of public safety. The Supreme Court reversed the Court of Appeals' decision and remanded the case with directions to affirm the district court's order. View "State v. Jeremiah T." on Justia Law

A twelve-year-old child disclosed to a school counselor that she had been communicating with a twenty-six-year-old man, later identified as Eric Overton, via Snapchat. The child’s mother confirmed the communication, obtained evidence from the phone, and contacted law enforcement. The investigation revealed that Overton and the child had exchanged nude photographs and sexually explicit messages, and that Overton had picked up the child from her home on three occasions, during which they engaged in sexual intercourse. The child provided detailed testimony at trial regarding these encounters.The Hot Spring County Circuit Court presided over the trial, during which Overton objected to the prosecutor’s voir dire questioning about whether a conviction could be based on the testimony of a single credible witness. The court overruled the objection and denied a subsequent motion for mistrial, emphasizing that the jury would be instructed on the law at the end of the case. The jury was later instructed on the presumption of innocence and the State’s burden of proof beyond a reasonable doubt. The jury found Overton guilty of rape and internet stalking of a child, and he was sentenced to life imprisonment on each count.On appeal, the Supreme Court of Arkansas reviewed whether there was substantial evidence to support the rape conviction and whether the circuit court erred in its handling of voir dire and jury instructions. The court held that the evidence, including the victim’s testimony, was sufficient to support the conviction, and that the circuit court did not abuse its discretion in denying the mistrial. The court affirmed the convictions, finding no prejudicial error in the proceedings. View "Overton v. State" on Justia Law

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