Justia Juvenile Law Opinion Summaries

Defendant, a juvenile, appealed from the judgment of the district court which imposed, as a condition of his juvenile delinquent supervision, that he register under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901 et seq. The court held that the district court did not err by imposing the sex offender registration condition because the court concluded that Congress, in enacting SORNA, intentionally carved out a class of juveniles from the Federal Juvenile Delinquency Act's, 18 U.S.C. 5031 et seq., confidentiality provisions, and that SORNA's registration requirements were not punitive as applied to defendant. View "United States v. Under Seal" on Justia Law

Defendant pleaded guilty to three counts of first-degree robbery. Defendant was a minor at the time he committed the felonies, and because the offenses involved a firearm, Defendant was automatically transferred to the circuit court as a youthful offender to be tried as an adult. The trial court determined Defendant should be granted probation on his ten-year sentence. The trial court subsequently revoked Defendant's probation and sentenced him to the Department of Corrections (DOC) to serve his sentence. The DOC classified Defendant as a violent offender, a status that restricted Defendant's parole eligibility. Defendant filed a declaration of rights action, arguing that the DOC erred in classifying him as a violent offender because he was a youthful offender. The circuit court agreed. The court of appeals reversed, holding that the Violent Offender Statute applied to youthful offenders for purposes of parole eligibility. The Supreme Court affirmed, holding (1) the parole-eligibility limitations of the Violent Offender Statute apply to youthful offenders; and (2) therefore, the DOC correctly classified Defendant as a violent offender subject to that statute's parole-eligibility restrictions. View "Edwards v. Harrod" on Justia Law

In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law

In 1996 mother reported to police that, during a visit to her father’s apartment, their 12-year-old (Linda) alleged that father made sexual advances. Mother obtained an order of protection after he twice failed to appear. The county agency classified father as an “indicated” child abuse perpetrator on Pennsylvania’s child abuse registry. Father was charged with indecent exposure and endangering a child’s welfare. He pled guilty to harassment; the remaining charges were dismissed. In subsequent years, Linda denied the incident. Mother and father resumed living together and were allowed, by the agency, to have related children in their home. After mother obtained custody of their grandchild, the agency removed all children from the home, based on father’s listing. By the time father attempted to appeal in 2007, the agency had destroyed its 1996 records. The listing was expunged in 2010. The district court rejected claims under 42 U.S.C. 1983. The Third Circuit affirmed, finding that the agency’s position with respect to the listing did not “shock the conscience” and that there was no showing of a deliberate decision to deprive the plaintiff of due process nor evidence that the agency employs a policy or has a custom of conducting desultory investigations. View "Mulholland v. Cnty. of Berks" on Justia Law

Defendant, a juvenile male, was charged with second-degree murder and using a firearm during a crime of violence. Defendant was seventeen years old at the time of the alleged offenses. On appeal, defendant challenged the district court's order granting the government's motion to transfer juvenile proceedings for adult prosecution under 18 U.S.C. 5032. The court held that the district court did not abuse its discretion by making findings regarding defendant's intellectual development and psychological maturity; the district court did not abuse its discretion by making a finding about the alleged discrepancy in individualized attention and counseling programs when comparing the adult and juvenile detention systems; and the district court's presumption of guilt for purposes of the transfer decision did not violate defendant's due process rights. Accordingly, the court affirmed the judgment. View "United States v. JJ, Juvenile Male" on Justia Law

Defendant, who was a juvenile at the time of the offense, was indicted for murder in the second degree. The superior court judge dismissed the indictment on the ground that the Commonwealth presented insufficient evidence to the grand jury to support an indictment of murder in the second degree. A majority of the Supreme Court affirmed the order dismissing the indictment, holding (1) contrary to the superior court judge's ruling, the evidence before the grand jury supported the indictment for murder in the second degree; but (2) the grand jury should have been, but was not, instructed by the prosecutor on the elements of murder and on the legal significance of the mitigating circumstances raised by the evidence. View "Commonwealth v. Walczak" on Justia Law

Appellee committed an act on September 1, 2007 that, if committed by an adult, would constitute rape. On May 19, 2010, the juvenile court classified Appellee as a Tier III sex offender under S.B. 10. Appellee appealed, asserting that he should not be classified as a Tier III sex offender under S.B. 10 because he committed his offense before the effective date of the applicable part of that statute. The First District Court of Appeals agreed and reversed. Noting, however, that its analysis was in conflict with the analysis of the Eighth District Court of Appeals, the First District certified a question of law to the Supreme Court. The Supreme Court answered by stating that S.B. 10's classification, registration, and community-notification provisions may not be constitutionally applied to a sex offender who committed his sex offense between the July 1, 2007 repeal of Megan's Law and the January 1, 2008 effective date of S.B. 10's aforementioned provisions. View "In re Bruce S." on Justia Law

In 2009, the State filed a petition against John Doe, charging that he was within the purview of Idaho's Juvenile Corrections Act (JCA) for delivery of a schedule III controlled substance, hydrocodone. The State and Doe's counsel reached an agreement whereby Doe admitted to the charge and, in exchange, the State waived proceedings to bring Doe into adult court. At the conclusion of Doe's sentencing hearing, the magistrate judge memorialized his ruling in a "decree" that was issued that same day. The decree stated, "It is hereby Ordered, Adjudged and Decreed that [Doe] is within the purview of the [JCA] and shall be placed on Formal Probation supervision not to exceed 2 years." In the first year of Doe's probation, he had two probation review hearings, both of which demonstrated good behavior. At Doe's one-year probation review hearing, Doe's counsel argued that the magistrate should convert his formal probation to an informal adjustment. Doe's counsel could not cite any authority for converting the sentence, but believed that the court had broad authority to do so based on the interests of justice. The State objected and argued that the court did not have authority to convert the formal probation to an informal adjustment. Ultimately, the magistrate court stated that it had the authority to convert the sentence and entered a "supplemental decree nunc pro tunc to date of original order," granting Doe an informal adjustment and dismissing the case. The magistrate then issued an Order Supplementing Decree that provided "Formal Probation converted to Informal Adjustment, nunc pro tunc 05/05/09." The State filed an appeal to the district court. The district court affirmed the magistrate court's order. The State timely appealed to the Supreme Court. Because it was improper for the magistrate to convert Doe's sentence, any subsequent dismissal or termination of the improperly substituted informal adjustment could not be upheld. The Supreme Court reversed the district court's order and remanded the case for reinstatement of the 2009 decree. View "Idaho v. Doe (2012-09)" on Justia Law

Murdock, then 16, was convicted in 2001 of first degree murder and aggravated battery with a firearm. The conviction was affirmed. Defendant filed a post-conviction petition alleging trial counsel was ineffective for failing to move to suppress statements made to police. Defendant, a juvenile, alleged his statements were the product of police coercion that rendered them involuntary. After an evidentiary hearing, the trial court denied defendant’s petition. The appellate court reversed and remanded for a suppression hearing. The trial court denied the motion on remand. The appellate court affirmed. The Illinois Supreme Court affirmed, rejecting an argument based on the absence of a concerned adult during defendant's police detention. Defendant was able to clearly communicate and understand the questions posed to him. He was able to understand and give assent to a waiver of his Miranda rights. On tape defendant appeared mostly calm and collected. He did not appear frightened or under any intense coercion. Defendant was never threatened physically or mentally and there were no promises or assurances to defendant to contribute to a coercive atmosphere. Defendant was allowed access to food, drink, and restroom; his statements were the result of his own decisions. View "People v. Murdock" on Justia Law

Respondent was adjudicated delinquent and committed to a state facility. While there, he allegedly battered a group supervisor. The State charged him as an adult with battery by a prisoner under Nev. Rev. Stat. 200.481(2)(f), a felony. Citing relevant statutes and Robinson v. State, which broadly holds that "prisoner" as used in section 200.481(2)(f) was meant to only apply in the criminal setting, the district court dismissed the charge, holding that because Respondent's detention was civil, not criminal, he was not a "prisoner" to whom section 200.481(2)(f) could apply. The State appealed. The Supreme Court affirmed, holding that a juvenile detained for delinquency in a state facility is not a "prisoner" for purposes of section 200.481(2)(f). View "State v. Javier C." on Justia Law