Justia Juvenile Law Opinion Summaries

The case revolves around a defendant who was convicted for enticement of a child. The defendant had approached a ten-year-old girl, A.W., while she was walking her dog. He drove into the opposing lane of traffic to pull his truck up beside her, asked her personal questions, and made inappropriate comments. Based on these events and evidence of the defendant’s previous behavior with a five-year-old girl in Louisiana, a jury convicted the defendant of enticement of a child.The defendant appealed his conviction, arguing that the evidence was insufficient to prove the offense of enticement. The court of appeals agreed with the defendant's argument, vacating his conviction on the ground that the evidence was insufficient to prove that the defendant had attempted to invite or persuade A.W. to enter his truck, or that he intended to commit unlawful sexual contact.The Supreme Court of the State of Colorado disagreed with the court of appeals' interpretation of the term "attempt" in the child enticement statute. The Supreme Court held that the term "attempt" in the statute should be interpreted according to its plain meaning, not as referring to the inchoate crime of "attempt" defined in another statute. The Supreme Court found that the defendant's words and actions, taken together and viewed in the light most favorable to the prosecution, constituted sufficient evidence for a reasonable person to conclude that the defendant attempted to invite or persuade the victim to enter his vehicle with the intent to commit unlawful sexual contact upon her. Therefore, the Supreme Court reversed the court of appeals’ decision vacating the defendant’s conviction and remanded the case to the court of appeals to address his remaining appellate arguments. View "People v. Johnson" on Justia Law

The case involves a juvenile, Jeovani H., who was placed on probation and ordered to pay restitution as a term and condition of his probation. Jeovani was charged with an act that would constitute the felony of first-degree assault, which was later amended to a misdemeanor of attempted third-degree assault. The incident involved Jeovani shoving another youth, causing the youth to fall and fracture his arm. As part of a plea agreement, Jeovani admitted to the amended petition and agreed that the amount of restitution owed to his victim for medical expenses was $2,553.05. However, he disputed his ability to pay that amount.The Hall County Court, sitting as a juvenile court, accepted Jeovani’s admission to the amended petition and ordered a predisposition investigation. At the disposition and restitution hearing, Jeovani’s mother testified about the family's financial situation and work schedules, arguing that Jeovani did not have the ability to pay the restitution amount. The State called Jeovani and a juvenile probation officer as witnesses, who testified about Jeovani's ability to work and earn money to pay the restitution.The Nebraska Supreme Court affirmed the juvenile court's decision. The court found that Jeovani had the ability to pay the restitution within the 12-month period of his probationary term. The court also rejected Jeovani’s claim that he was not allowed an opportunity to present or cross-examine witnesses on the issue of restitution. The court concluded that the restitution order was consistent with Jeovani’s reformation and rehabilitation and was supported by the record. View "In re Interest of Jeovani H." on Justia Law

The case revolves around Joshua Reber, who was convicted for sexually abusing a young child. The child, K.W., testified in detail about the abuse, which began when she was eight years old. Reber admitted to taking K.W. into the woods alone at night without informing anyone but denied any sexual abuse. During his testimony, Reber also discussed his normal sexual relationships with adult women. The prosecutor cross-examined Reber about his text messages with a woman named Danielle, which indicated sexual encounters. Reber did not object to these questions.The jury found Reber guilty, and he was sentenced to two consecutive terms of 300 to 420 months in prison. Reber appealed, arguing that the admission of his cross-examination testimony and the prosecutor's statements during closing arguments were errors. The Court of Appeals reversed Reber’s convictions, holding that the introduction of the challenged evidence on cross-examination amounted to plain error and that the prosecutor’s statements during closing argument were so grossly improper that the trial court should have intervened on its own initiative.The Supreme Court of North Carolina disagreed with the Court of Appeals' decision. The court held that the admission of the cross-examination testimony was not plain error and that the prosecutor's statements during closing arguments were not so grossly improper that the trial court should have intervened. The court reversed the decision of the Court of Appeals and remanded the case for consideration of Reber’s remaining arguments. View "State v. Reber" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

The case involves a minor, Randy C., who was stopped by police for driving a car with illegally tinted windows. During the stop, the officer smelled unburnt marijuana and observed a marijuana blunt on the passenger's lap. The officer conducted a search of the vehicle, finding a handgun in the glove compartment and an AR-15 firearm in the trunk. Randy C. was subsequently charged with multiple felony offenses, including possession of an assault weapon by a minor and possession of a concealed firearm and ammunition in a vehicle by a minor. He moved to suppress the evidence, arguing there was no probable cause to search the vehicle.The juvenile court denied Randy C.'s motion to suppress the evidence. Following this ruling, Randy C. admitted to the felony offenses charged, and the remaining counts were dismissed pursuant to a negotiated plea deal. The juvenile court declared wardship and committed Randy C. to juvenile hall for 274 days with 55 days of credit for time served. Randy C. appealed the denial of his motion to suppress, arguing that the search and seizure conducted by police were unlawful.The Court of Appeal of the State of California First Appellate District affirmed the juvenile court's decision. The court held that the officer had probable cause to search the vehicle based on the smell of unburnt marijuana and the observation of a marijuana blunt in the passenger's lap, which was considered an open container of marijuana in violation of the law. The court rejected Randy C.'s argument that the marijuana blunt was not an "open container" within the meaning of the law, concluding that the paper wrapping enclosing the marijuana presented no barrier to accessing the marijuana, thereby facilitating its consumption. View "In re Randy C." on Justia Law

The case involves a juvenile, J.L.J., who was charged with first-degree felony murder and several other offenses after he opened fire on a car, killing a 12-year-old boy. J.L.J. was certified for adult prosecution and testified that he was acting in self-defense. The jury rejected his self-defense claim and convicted him on all charges.The case was previously heard in the Leavenworth District Court where J.L.J. was convicted. On appeal, J.L.J. raised several claims of error, including prosecutorial errors and the argument that the State unconstitutionally pitted his right to prepare for his defense against his right to testify at trial.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court found that while the prosecutor erred by asking potential jurors if they would do their "job" and convict J.L.J., this error was harmless and did not affect the jury's verdict. The court also disagreed with J.L.J.'s argument that the prosecutor misstated the law on self-defense during closing argument. Furthermore, the court found that the State's impeachment of J.L.J. did not violate the unconstitutional-conditions doctrine. Lastly, the court declined to invoke an exception to the general preservation rule to address J.L.J.'s argument that the adult certification process violates his constitutional rights. View "State v. J.L.J." on Justia Law

The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

Jesse McCollaugh was found guilty of child exploitation after his wife discovered videos on his phone of her 15-year-old sister using the bathroom, which McCollaugh had secretly recorded. The videos showed the minor partially nude, unaware she was being filmed. McCollaugh admitted to recording the videos and having a sexual problem. He was charged with one count of sexual exploitation of a minor, to which he pleaded not guilty. After a bench trial, the district court found McCollaugh guilty and sentenced him to a prison term not exceeding two years, and required him to register as a sex offender.Before the Supreme Court of Iowa, McCollaugh appealed his conviction, arguing that the evidence was insufficient to support his conviction because it failed to establish that the minor had the purpose of engaging in nudity to arouse or satisfy the sexual desires of a person who may view the visual depiction. The Supreme Court disagreed with McCollaugh's interpretation of the statute, stating that the relevant "purpose" that the State must prove is identified after the word "purpose" in the definition, not before. The court held that the State must prove the purpose of purchasing or possessing a visual depiction of the nude minor—not the minor’s purpose in being nude. The court found sufficient evidence to prove McCollaugh’s purpose for taking the videos was for his sexual gratification and affirmed his conviction. McCollaugh also argued that the district court relied on an improper factor in its sentencing order, but the Supreme Court found no evidence that the district court relied on the improper factor and affirmed the sentence. View "State v. McCollaugh" on Justia Law