Justia Juvenile Law Opinion Summaries

Articles Posted in Criminal Law
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The defendant, Darion Thomas, was arrested at a hospital in Iowa while accompanying his sick child and the child's mother, Tyliyah Parrow. During the arrest, law enforcement found a gun on Thomas and a backpack containing drugs. The backpack was searched after Parrow gave her consent. Thomas's cell phone, which was in Parrow's possession, was also seized and searched after a warrant was obtained five days later. Thomas was charged with possession with intent to distribute a controlled substance and possession of a firearm in furtherance of a drug trafficking crime. He pleaded guilty but reserved his right to appeal the denial of his motion to suppress evidence obtained from the backpack and cell phone.The district court denied Thomas's motion to suppress the evidence, ruling that Parrow had the authority to consent to the search of the backpack and that her consent was voluntary. The court also found that the five-day delay in obtaining a search warrant for the cell phone was reasonable. At sentencing, the court applied a two-level enhancement based on text messages that showed Thomas had supervised a minor in drug transactions.On appeal to the United States Court of Appeals for the Eighth Circuit, Thomas argued that the district court erred in its rulings on the search of the backpack, the delay in obtaining the search warrant for the cell phone, and the application of the two-level enhancement. The appellate court affirmed the district court's decisions, finding no clear error in its factual findings or legal conclusions. The court held that Parrow's consent to the search of the backpack was voluntary, the delay in obtaining the search warrant for the cell phone was reasonable, and the application of the two-level enhancement was justified based on the evidence presented. View "United States v. Thomas" on Justia Law

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In 2016, 21-year-old Kwame De-Markquise Morrison initiated a sexual relationship with a 12-year-old girl, A.M. In 2017, A.M. became pregnant and gave birth to a child, who was later adopted. Morrison was charged with six counts of sexual assault upon a minor under 14 years of age and one count of use of a minor under the age of 14 in producing pornography. Morrison admitted to having sex with A.M. but claimed he believed she was 16 years old.The district court convicted Morrison of three counts of sexual assault upon a minor under 14 years of age and one count of use of a minor under the age of 14 in producing pornography. The court instructed the jury that a lack of knowledge or a mistake as to the victim's age is not a defense to a charge of using a minor in producing pornography. Morrison appealed, arguing that the instruction was inaccurate because the State is required to prove that the defendant "knowingly" used "a minor" in producing pornography.The Court of Appeals of Nevada agreed that the instruction was inaccurate. However, it found that the error was harmless beyond a reasonable doubt because Morrison admitted that he believed A.M. was 16 years old—and therefore a minor—during their sexual relationship. The court also rejected Morrison's other claims on appeal, including that the district court abused its discretion by denying his motion to dismiss counsel and that the State committed prosecutorial misconduct. Therefore, the court affirmed Morrison's judgment of conviction. View "Morrison v. State" on Justia Law

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In this case, the Supreme Court of Pennsylvania was tasked with interpreting the definition of “nudity” as used in 18 Pa.C.S. § 6321. The case involved a minor, T.Q.B., who encouraged another minor, A.D., to lift her shirt during an Instagram live video. A.D., who has an intellectual disability, exposed the bottom portion of her breasts below the nipple area. The rest of A.D.’s breasts, including the nipple, were covered by a bra. T.Q.B. was charged with transmission of sexually explicit images by a minor, a second-degree misdemeanor under 18 Pa.C.S. § 6321(c). T.Q.B. argued that the nudity element of the statute had not been established because the nipple was not exposed.The trial court adjudicated T.Q.B. delinquent, interpreting the statute to cover the exposure of any part of the breast below the nipple. On appeal, the Superior Court affirmed, determining that the term "nudity" in the statute does not require that the nipple must be exposed for the offense to be committed.The Supreme Court of Pennsylvania affirmed the lower courts' decisions. The court found that the language of Section 6321(g) does not require exposure of the nipple to establish the element of nudity. The court held that nudity is sufficiently established where any area below the top of the nipple is visible. The court concluded that the clear language of the statute and the evidence presented at the adjudication hearing established the nudity requirement, and affirmed the Superior Court’s dispositional order finding the evidence sufficient to support T.Q.B.’s adjudication of delinquency. View "In the Int of: T.Q.B., a Minor; Apl of: T.Q.B." on Justia Law

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In this case conducted by the Supreme Court of Mississippi, the defendant, Keith Montrago Jackson, was charged and convicted of sexual battery and sentenced to life imprisonment. The case stemmed from an incident involving Jackson and his girlfriend's twelve-year-old daughter, Anna. Jackson and Anna went to a store late at night, and upon their return, Jackson sexually assaulted Anna in his truck. Anna reported the incident to her school, and law enforcement was contacted.At trial, Anna testified about the incident and identified Jackson as the perpetrator. Forensic evidence, including sperm cells found in Anna that matched Jackson's DNA, was presented. Jackson testified in his own defense, denying the allegations. However, he was convicted and sentenced to life imprisonment.Jackson appealed the conviction, but his appellate counsel found no arguable issues for appellate review. The Court, having independently reviewed the record, also found no arguable issues. The Supreme Court of Mississippi affirmed the trial court's judgment. View "Keith Montrago Jackson a/k/a Keith Jackson v. State of Mississippi" on Justia Law

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This case before the Indiana Supreme Court concerns a juvenile, A.W., who was adjudicated for possession of a machine gun and dangerous possession of a firearm. The court was asked to determine if these adjudications violated the principle of double jeopardy under Indiana law. A.W. asserted that he did not know the firearm he possessed had been modified to function as a machine gun.The court found that A.W.'s exclusive possession of the modified gun, along with his abrupt flight from police, supported the conclusion that he knowingly or intentionally possessed a machine gun. This satisfied the first part of the court's inquiry.On the issue of double jeopardy, the court noted that while the Indiana Constitution could apply in juvenile proceedings, it avoided deciding that issue. Instead, it focused on whether possession of a dangerous firearm is a lesser-included offense of possession of a machine gun under the test set out in the case Wadle v. State. The court found that it was, meaning A.W.'s adjudications for both offenses violated his rights under the principle of double jeopardy. Therefore, the court affirmed the finding that A.W. knowingly possessed a machine gun but reversed the adjudication that he committed dangerous possession of a firearm. View "A. W. v. State of Indiana" on Justia Law

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This case involves the multiple appeals of a juvenile, Miguel R., who was transferred to criminal court for alleged felonies including murder and second-degree robbery. A juvenile wardship petition alleged that Miguel committed these crimes when he was 17 years old. The juvenile court initially granted the People’s motion to transfer Miguel to criminal court. Miguel appealed this order, but the decision was affirmed. Following the remittitur issue, the juvenile court transferred the matter to criminal court.However, subsequent amendments to section 707 of the Welfare and Institutions Code necessitated a second transfer hearing. The amendments raised the standard of proof to clear and convincing evidence on the issue of whether a juvenile should be transferred. The juvenile court, after considering the statutory changes, again ordered Miguel to be transferred to criminal court based on the conclusion that he was “not amenable to the care, treatment and training programs available through the juvenile court system”. Miguel appealed this order as well, arguing that the juvenile court misapplied the statutory changes and that the prosecution did not carry its burden under the clear and convincing evidence standard.The court of appeal rejected Miguel’s arguments and affirmed the juvenile court's decision. The court held that the juvenile court was not required to give greater weight to any particular statutory criterion in its determination of whether a minor is amenable to rehabilitation. The court also found that substantial evidence supported the juvenile court's findings. Thus, the order transferring Miguel to criminal court was affirmed. View "In re Miguel R." on Justia Law

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This case involves the appeal of an order to transfer a juvenile, Miguel R., from the juvenile court system to the criminal court system in California. Miguel was originally charged with murder and other offenses when he was 17 years old. After a juvenile wardship petition was filed, the juvenile court granted a motion to transfer Miguel to the criminal court. The defendant appealed this order, but it was affirmed by the appellate court.Subsequently, changes in legislation led to the case being transferred back to the juvenile court to address the statutory amendments. The juvenile court, applying the new standard of proof, again ordered Miguel to be transferred to the criminal court. Miguel appealed this second order, arguing that the juvenile court misapplied the statutory changes and that the prosecution did not meet its burden under the clear and convincing evidence standard.The appellate court affirmed the order of the juvenile court. It clarified certain points about the recent amendments to the relevant statute, stating that the statute does not require any one factor to be given more weight than others when determining whether a minor is suitable for rehabilitation under the juvenile court's jurisdiction.The appellate court also found that the juvenile court's decision to transfer Miguel to the criminal court was supported by substantial evidence, and that it was not reasonably probable that the juvenile court would have reached a different conclusion even if it had applied the most recent version of the statute. The court's ruling was based on factors such as Miguel's degree of criminal sophistication, his potential for rehabilitation before the expiration of the juvenile court's jurisdiction, the success of previous attempts to rehabilitate him, and the circumstances and gravity of his offenses. View "In re Miguel R." on Justia Law

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In this case, the Supreme Court of Ohio considered whether a juvenile, T.D.S., knowingly, intelligently, and voluntarily waived his Miranda rights before providing statements to the police. The statements related to a homicide investigation involving another juvenile.The case originated from an incident in 2019, where the Police responded to a report of shots fired in an apartment building and discovered a male juvenile, S.G., with gunshot wounds. The police investigation led them to T.D.S., who was then 15 years old. During questioning at T.D.S.'s mother’s house, T.D.S. initially denied involvement in the shooting but later admitted to accidentally shooting S.G. while playing with a gun. After these statements, T.D.S. was read his Miranda rights and questioned further. He was subsequently charged with several offenses including murder and felonious assault.T.D.S. argued that the juvenile court should have granted a motion to suppress all the statements he made to the police officers, contending that he did not knowingly, intelligently, and voluntarily waive his Miranda rights. After considering the totality of the circumstances, including T.D.S.'s age, prior criminal experience, and the nature of the police interrogation, the Supreme Court of Ohio affirmed the lower courts' decisions that T.D.S. had knowingly, intelligently, and voluntarily waived his Miranda rights. The court found that the police did not engage in coercion and that T.D.S.'s waiver was not involuntary.T.D.S. also argued that his post-Miranda statements should be presumed inadmissible under the court's previous reasoning in a case called State v. Farris. However, the court found that T.D.S. had not properly raised this argument in the lower courts, so it was forfeited. Even if he had preserved the argument, the court found that the record did not support his claims under the Farris case.Therefore, the court affirmed the judgment of the lower courts, finding that T.D.S.'s post-Miranda statements were properly admitted at trial. View "In re T.D.S." on Justia Law

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In 1980, Thernell Hundley was convicted of capital murder and rape, and received a life sentence without parole. In 2012, the Supreme Court ruled that life sentences without parole for juvenile offenders were unconstitutional, and Hundley's life sentence for capital murder was vacated. However, during his incarceration, Hundley had committed four additional felonies. As a result, the Jefferson County Circuit Court in Arkansas ruled that Hundley was ineligible for parole based on Arkansas Code Annotated section 16-93-607(c)(5), which states that inmates classified as fourth offenders are not eligible for parole.Hundley appealed this decision, arguing that his rape conviction should be vacated as it was merged with the capital murder charge, that he should be eligible for parole under the Fair Sentencing of Minors Act, and that his parole eligibility should be determined by the law in effect when he committed his first crimes in 1979. He also challenged the inclusion of his two Class D felony convictions in determining his parole eligibility.The Supreme Court of Arkansas upheld the circuit court's decision. The court ruled that Hundley's separate conviction for rape was not illegal and could not be vacated. The court further held that Hundley's parole eligibility was correctly determined based on the law in effect at the time he committed his last two felonies in 1988 and 1989, not the law at the time of his original crimes. The court also clarified that Hundley's parole ineligibility was based on his convictions for capital murder, rape, attempted first-degree murder and first-degree battery, not his two Class D felonies. View "Hundley v. Payne" on Justia Law

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In this juvenile wardship proceeding in California, defendant M.B. admitted to attempting murder and related enhancement allegations. M.B. was committed to a secure youth treatment facility (SYTF) for a four-year baseline term of confinement and a maximum term of confinement of 22 years to life. On appeal, M.B. challenged the court's jurisdiction to modify an earlier order setting the maximum term of confinement at four years. He also argued that the indeterminate 22 years to life term was unauthorized and that his precommitment credits should be applied against his four-year baseline term rather than against the maximum term of confinement.The Court of Appeal held that the juvenile court had jurisdiction to enter the challenged order and rejected M.B.'s argument that equal protection principles required application of precommitment credits against the baseline term. However, the court agreed with M.B. and the Attorney General that the 22 years to life maximum term of confinement was unauthorized. As such, the court modified the juvenile court's order to specify the maximum term of confinement as 22 years and otherwise affirmed the order. View "In re M.B." on Justia Law