Justia Juvenile Law Opinion Summaries

A 16-year-old girl, Luna, was involved in a fatal altercation with another teenager, S.P.T., whom she knew only through social media. The conflict began when S.P.T. arrived at Luna’s home and initiated a physical fight by punching Luna. Luna responded by using a pocketknife, resulting in S.P.T.’s death. Prior to the incident, Luna had received social media messages that she interpreted as threats, including an image suggesting gang violence. The State charged Luna with murder, and she was tried as an adult.In the Kitsap County Superior Court, the State was permitted to introduce various pieces of social media evidence and a video of Luna’s police interrogation to suggest preexisting violent intent and lack of remorse. Luna argued self-defense and sought to introduce additional social media evidence to support her fear of S.P.T., but some of this evidence was excluded. The jury found Luna guilty of intentional, but not premeditated, second-degree murder. On appeal, the Washington Court of Appeals affirmed the conviction, finding that some social media evidence was improperly admitted but deemed the error harmless. The appellate court also held that a new statute requiring juveniles to be provided counsel before interrogation did not apply retroactively to Luna’s case.The Supreme Court of the State of Washington reviewed the case. It held that the new statute, RCW 13.40.740, did not apply retroactively to Luna’s interrogation. However, the court found that Luna did not validly waive her right to silence, and her interrogation statements should have been excluded. The court also determined that several evidentiary rulings regarding social media evidence were erroneous and undermined the fairness of the trial. The Supreme Court vacated the jury verdict and remanded the case for further proceedings. View "State v. Luna" on Justia Law

A defendant committed several serious offenses, including first-degree murder and attempted murder, when he was 17 years old. In 2002, a jury convicted him of these crimes, and he was sentenced to a total term of 79 years to life with the possibility of parole. The sentence included both determinate and indeterminate terms, with firearm enhancements. The crimes occurred in 2000, and the defendant was not sentenced to life without the possibility of parole (LWOP), but rather to a lengthy term that could be considered the functional equivalent of LWOP.Years later, the defendant filed a petition in the Superior Court of Ventura County seeking recall of his sentence under Penal Code section 1170, subdivision (d)(1)(A), which allows for resentencing of juvenile offenders sentenced to LWOP. The trial court granted the petition, reasoning that the defendant’s 79-year-to-life sentence was functionally equivalent to LWOP, relying on the reasoning in People v. Heard (2022) 83 Cal.App.5th 608 and People v. Sorto (2024) 104 Cal.App.5th 435. The court recalled the sentence, conditionally reversed the conviction and sentence, and certified the matter to juvenile court for further proceedings under Proposition 57. Meanwhile, the defendant received a youth offender parole hearing under Penal Code section 3051, but was found unsuitable for parole.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It held that the defendant was not eligible for relief under section 1170(d)(1)(A) because he was not sentenced to LWOP, and that subsequent legislative changes, specifically section 3051, rendered the Heard rule moot. The court concluded that since the defendant had already received a parole hearing, he was not serving the functional equivalent of LWOP. The appellate court reversed the trial court’s orders. View "P. v. Lara" on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

John Doe, a Native American juvenile and member of the Eastern Shoshone Tribe, was charged in federal court with multiple offenses, including kidnapping a minor on tribal land for the purpose of physical assault. The government filed a six-count juvenile information, and Doe admitted to certain charges, including kidnapping, assault with a dangerous weapon, and provided a factual basis for his admissions. The events occurred in a trailer on the Wind River Indian Reservation, where Doe assaulted two minor victims and instructed one to remain in a closet as he left the scene.The United States District Court for the District of Wyoming held an admission hearing, where Doe, with counsel, admitted to the relevant charges. The court found a sufficient factual basis and conditionally accepted the admissions. After a delinquency hearing, Doe was adjudicated delinquent on several counts and committed to detention and supervision. Following the district court’s judgment, the Tenth Circuit decided United States v. Murphy, which clarified that the “holds” element of federal kidnapping requires proof the victim was detained for an appreciable period beyond that necessary to commit any related offense. Doe appealed, arguing his admission was not knowing or voluntary because he was not informed of this temporal requirement.The United States Court of Appeals for the Tenth Circuit reviewed the case under the plain error standard. The court held that Murphy did not clearly establish the temporal requirement as an essential element of kidnapping, nor did Doe demonstrate that the district court’s failure to inform him of this requirement was a plain error under well-settled law. The court affirmed the district court’s judgment of delinquency. View "United States v. Doe" on Justia Law

A defendant was convicted of first-degree murder and attempted murder for crimes committed at age 17, alongside an adult codefendant. The jury found true allegations of gang involvement and personal use of a firearm, resulting in an aggregate sentence of 75 years to life, plus additional time for unrelated carjacking offenses. After serving 15 years, the defendant petitioned for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole and that he met several statutory eligibility criteria, including having committed the offense with an adult codefendant.The Superior Court of Los Angeles County reviewed the petition, held a hearing, and denied relief. The court found that none of the eligibility criteria were satisfied, reasoning that the adult codefendant’s conviction had been vacated under a separate statute and that the defendant had not shown sufficient rehabilitation. The court also considered the defendant’s juvenile record and prison disciplinary history, concluding that he lacked potential for rehabilitation.On appeal, the California Court of Appeal, Second Appellate District, Division Four, reviewed the trial court’s factual findings for substantial evidence and interpreted the statutory language de novo. The appellate court held that the defendant satisfied the criterion of having committed the offense with an adult codefendant, as the adult was charged and convicted for the same incident, even though her conviction was later vacated due to a change in law. The court reversed the trial court’s order denying the petition and remanded the case for a resentencing hearing in accordance with section 1170(d), without expressing an opinion on the appropriate sentence. View "People v. Gomez" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

A deadly shooting occurred at a house party in Las Cruces, New Mexico, in July 2021. During a chaotic altercation, multiple gunshots were fired, resulting in the death of Nicodemus Gonzales and damage to a vehicle driven by Jayissa Borrunda. Eyewitnesses described seeing the defendant and his cousin brandishing guns with laser sights. Forensic evidence was inconclusive as to which weapon caused the fatal injury. The defendant, who was seventeen at the time, was charged as a Serious Youthful Offender with first-degree (willful and deliberate) murder and other related offenses.The District Court of Doña Ana County acquitted the defendant of first-degree (willful and deliberate) murder but allowed the case to proceed to the jury on first-degree felony murder, predicated on aggravated assault, as well as other charges. The jury convicted the defendant of first-degree felony murder (as an accomplice to aggravated assault), aggravated assault, two counts of conspiracy, and shooting at a motor vehicle. The court imposed a thirty-year sentence for felony murder, an enhanced sentence for aggravated assault, and additional concurrent sentences for the other convictions.The Supreme Court of the State of New Mexico reviewed the case. It held that aggravated assault is a noncollateral felony and cannot serve as the predicate for felony murder; therefore, the defendant’s felony murder conviction must be vacated as a legal nullity. The Court further held that double jeopardy does not bar retrial for felony murder or its lesser-included offenses when a conviction is reversed for a nonexistent crime, as this constitutes trial error rather than an acquittal. The Court also vacated one conspiracy conviction for lack of evidentiary support and reversed the four-year firearm enhancement as unauthorized by statute. The remaining convictions were affirmed, and the case was remanded for further proceedings consistent with the opinion. View "State v. Revels" on Justia Law

A group of teenagers and young adults devised a plan to rob and murder a man, Justin McKinney, and his girlfriend, Anna Franklin, as revenge for a drug-related incident involving one of the conspirators’ brothers. On the night of the crime, several of the group entered the victims’ home, where one participant shot and killed McKinney, and another shot and wounded Franklin. The group then fled, disposed of weapons, and made incriminating statements. Franklin survived and identified some of the assailants. Physical evidence, including firearms and shell casings, corroborated the events described by witnesses and participants.After the incident, several co-defendants pleaded guilty, while one was tried separately. The appellant, who was a juvenile at the time, was tried by a jury in the Superior Court of Fannin County and found guilty on all counts, including malice murder, attempted murder, and related offenses. He was sentenced to life in prison plus additional consecutive and concurrent terms. The trial court denied his motion for a new trial.The Supreme Court of Georgia reviewed the case. The appellant argued that his custodial statements should have been suppressed due to his age, learning disability, and other factors; that the trial court erred by modifying a pattern jury instruction to include “age” as a factor not to influence the jury; and that a post-incision autopsy photograph was improperly admitted. The Supreme Court of Georgia held that the trial court did not err in admitting the custodial statements, as the totality of the circumstances showed a knowing and voluntary waiver of rights. The Court also found no plain error in the jury instruction and no abuse of discretion in admitting the autopsy photograph. The convictions and sentences were affirmed. View "Hill v. State" on Justia Law

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

A juvenile, K.I.B., was adjudicated delinquent in June 2024 by the Juvenile Court of Burleigh County, South Central Judicial District, for promoting a sexual performance by a minor and possession of prohibited materials, both felonies under North Dakota law, as well as giving false information to law enforcement. In January 2025, the court held a hearing to determine whether K.I.B. was required to register as a sexual offender. The court found that K.I.B. had no prior sexual offender offenses and did not exhibit mental abnormality or predatory conduct during the commission of the offenses, and therefore exempted K.I.B. from the registration requirement.The State appealed the exemption order to the Supreme Court of North Dakota, arguing that the juvenile court erred in interpreting its discretion under N.D.C.C. § 12.1-32-15. The State asserted its standing to appeal based on statutory language and public safety interests. The Supreme Court reviewed the statutory interpretation de novo, focusing on whether the juvenile court had discretion to exempt K.I.B. from registration under the relevant statute.The Supreme Court of North Dakota held that N.D.C.C. § 12.1-32-15(2)(a) mandates registration for individuals adjudicated as felonious sexual offenders, including juveniles, unless the offense falls under a specific exception listed in subdivision (c), which did not apply to K.I.B. The court concluded that the juvenile court misapplied the law and abused its discretion by exempting K.I.B. from registration. The Supreme Court reversed the juvenile court’s order and remanded the case for entry of judgment consistent with its opinion, requiring K.I.B. to register as a sexual offender. View "Interest of K.I.B." on Justia Law