Justia Juvenile Law Opinion Summaries

The Commonwealth alleged that, at age 16-17, the defendant committed several crimes including acts of child rape. The defendant was not apprehended until he was 26 years old. The defendant moved to dismiss the youthful offender indictments because he had not been afforded a transfer hearing pursuant to G.L. c. 119, 72A, which states that prior to indictment, the judge must determine whether there is probable cause to believe that the defendant committed the offenses charged and, if so, either order the defendant discharged, if consistent with the protection of the public, or dismiss the case, if the public interest requires that the defendant be tried. The judge allowed the defendant's motion. The Supreme Judicial Court affirmed. Section 72A, states that, "[i]f a person commits an offense or violation prior to his seventeenth birthday, and is not apprehended until after his eighteenth birthday, the court, after a hearing, shall determine whether there is probable cause ...." The language, "after a hearing shall," is clear and unambiguous. Section 54, which states, "[t]he court shall proceed on the complaint or the indictment ... in accordance with [sections 55-72], inclusive," does not exempt the Commonwealth from complying with the requirements of section 72A. View "Commonwealth v. Nanny" on Justia Law

The state filed a delinquency petition in the Juvenile Court for the Parish of Orleans charging Defendant with distribution of heroin in violation of La.R.S. 40:966(A)(1). After a hearing, the court adjudicated Defendant delinquent and ordered him committed to the custody of the Department of Public Safety and Corrections for a period not to exceed one year. On appeal, the Fourth Circuit set aside the juvenile court's adjudication and disposition order on grounds that "any rational trier of fact, after viewing all of the evidence favorably to the prosecution, must have a reasonable doubt as to the Defendant's guilt." The Supreme Court granted the state's application for review and reversed the decision because the court of appeal erred in substituting its appreciation of the evidence presented at the delinquency hearing for that of the fact finder. View "In the interest of C.D." on Justia Law

A high school security officer arrested minor M.M. for vandalism. The county district attorney's office filed an amended petition alleging that the minor had resisted or delayed a public officer in violation of Cal. Penal Code 148(a)(1) and had committed misdemeanor vandalism. The juvenile court found a school security officer was a public officer within the meaning of section 148(a)(1), and found true the allegations that the minor had resisted or delayed a public officer and of misdemeanor vandalism. The court of appeal reversed, concluding that a school security officer is not a public officer within the meaning of section 148(a)(1). The Supreme Court reversed, holding that school security officers, like sworn peace officers, fall within the protection of section 148(a)(1). Remanded. View "In re M.M." on Justia Law

In each of two underlying cases, a 14-year-old was convicted of murder and sentenced to a mandatory term of life imprisonment without possibility of parole. The highest courts of Alabama and Arkansas upheld the sentences. The Supreme Court reversed. The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. Children are constitutionally different from adults for sentencing purposes. Their lack of maturity and underdeveloped sense of responsibility lead to recklessness, impulsiveness, and heedless risk-taking. They are more vulnerable to negative influences and lack ability to extricate themselves from horrific, crime-producing settings. A child’s actions are less likely to be evidence of irretrievable depravity. The mandatory penalty schemes at issue prevent the sentencing court from considering youth and from assessing whether the harshest term of imprisonment proportionately punishes a juvenile offender. Life-without-parole sentences share characteristics with death sentences, demanding individualized sentencing. The Court rejected the states’ argument that courts and prosecutors sufficiently consider a juvenile defendant’s age, background and the circumstances of his crime, when deciding whether to try him as an adult. The argument ignores that many states use mandatory transfer systems or lodge the decision in the hands of the prosecutors, rather than courts. View "Miller v. Alabama" on Justia Law

This matter involved two cases, one involving two youths who appeared in youth court for detention hearings and one involving an adult who pled guilty to driving under the influence in justice court. After appearing in district court, the youths filed motions to substitute district court judge, and the court denied the motions as untimely. After the adult pled guilty in justice court, she appealed only the justice court's denial of her pretrial suppression motion, which the district court denied as untimely. The Supreme Court granted a petition for writ of supervisory control for the youths and denied it for the adult, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court correctly denied the adult's motion for substitution of district court judge, as no right exists under Mont. Code Ann. 3-1-804 to substitute a district judge in an appeal of a specific pre-trial legal ruling from justice court. View "Bledsoe v. Dist. Court" on Justia Law

Appellant N.D. was a juvenile when he was adjudicated delinquent for commission of aggravated robbery and possession of a weapon. After N.D. escaped from the detention center, the State filed a felony information charging N.D. as an adult with capital murder, escape in the first degree, aggravated robbery, theft of property, and second-degree battery. After the Supreme Court reversed the criminal court's denial of N.D.'s motion to transfer his case to the juvenile court, the criminal court transferred N.D.'s case to juvenile court. The juvenile court subsequently entered a decision that N.D. be designated for extended juvenile jurisdiction (EJJ). N.D. appealed, asserting that the criminal court already declined to make such a designation, and because the Supreme Court did not reverse that refusal in N.D.'s first appeal, the issue was decided by law of the case. The Supreme Court affirmed, holding that the Court did not previously reach a decision or provide direction to the criminal court with respect to EJJ designation, nor did the criminal court make a decision regarding EJJ designation, and so the law-of-the case doctrine did not bar the juvenile court from granting the State's motion for an EJJ designation. View "N.D. v. State" on Justia Law

Sixteen-year-old C.B. was charged with the felony offenses of, inter alia, capital murder, aggravated robbery, first-degree escape, and theft of property. C.B. filed a motion to dismiss and to declare Ark. Code Ann. 9-27-318 unconstitutional and a motion to transfer to juvenile court. In challenging the constitutionality of section 9-27-318, C.B. contended that the statute, among other things, violated the separation of powers doctrine by improperly vesting in the local prosecuting attorney power to determine which court has initial jurisdiction over certain classes of juveniles. The circuit court denied both motions. The Supreme Court affirmed, holding (1) section 9-27-318 was constitutional; and (2) the circuit court did not clearly err in denying C.B.'s motion to transfer. View "C.B. v. State" on Justia Law

The juvenile was charged with delinquency by reason of armed robbery. He was identified as the robber by means of a photograph that the police had obtained from his public high school and claimed to have included in a photographic array shown to the alleged victim. The juvenile moved to suppress the identification. Without evidence of how the student identification cards and photographs were created and how and by whom they were used within and outside of the school, the court was not in a position to review the judge's conclusion that the juvenile had a reasonable expectation of privacy in the photograph and the legal consequences that followed from such a conclusion. Consequently, the court vacated the judge's allowance of the motion to suppress and remanded for further proceedings. View "Commonwealth v. Zachary Z., a juvenile" on Justia Law

At issue in these two consolidated appeals was whether the district court properly calculated the time period in which to file a motion for substitution of district judge in youth court and on an appeal from justice court. Petitioners, two youths who appeared in court or detention hearings and a defendant who pled guilty in justice court to driving under the influence, petitioned for writ of supervisory control, claiming that the district court incorrectly denied as untimely their motions for substitution of district court judge in those cases. The Supreme Court reversed in part and affirmed in part, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court properly calculated the time period in which to file a motion for substitution of district court on the appeal from justice court. View "Bledsoe v. Judicial Dist. Court" on Justia Law

The Commonwealth appealed from orders of a judge in the Juvenile Court dismissing two youthful offender indictments charging the juvenile with statutory rape. The juvenile has Asperger's Syndrome, as does the complainant. The judge ordered the dismissal after finding that the juvenile had suffered presumptive and actual prejudice from the "Commonwealth's willful and repeated failure to comply with discovery orders." The court concluded that, while the judge erred in dismissing the indictments on the ground that there was insufficient evidence presented to the grand jury, the judge did not abuse her discretion in deciding that dismissal of the youthful offender indictments with prejudice was necessary to cure the prejudice caused to the juvenile's right to a fair trial by the prosecutor's egregious misconduct in wilfully and repeatedly violating the discovery order. View "Commonwealth v. Washington W." on Justia Law