Justia Juvenile Law Opinion Summaries

The Supreme Court held that Defendant's sentence constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments to the United States Constitution and Ohio Const. art. I, 9 when he was convicted as a juvenile and the trial court failed to consider his youth as a mitigating factor in sentencing.Defendant was charged with allegedly committing acts which, if committed by an adult, would constitute the offense of complicity to aggravated murder and other crimes. After a jury trial, Defendant was found guilty of several charges, and the trial court sentenced him to an indefinite life sentence in prison with parole eligible after thirty-eight to forty-three years. The Supreme Court reversed, holding that the trial court's sentence was unconstitutional because the court failed to consider Defendant's youth as a factor in sentencing. View "State v. Morris" on Justia Law

The Supreme Court affirmed the judgment of the district court reducing Joshua Anderle's sentence for sexual abuse of a minor by two years following his completion of the Youthful Offender Transition Program, holding that the district court did not abuse its discretion by reducing Anderle's sentence by two years in recognition of his successful completion of the program.Anderle entered an Alford plea to second-degree sexual abuse of a minor. The district court sentenced him to eight to twelve years' imprisonment and recommended that the Wyoming Department of Corrections treat Anderle as a youthful offender under Wyo. Stat. Ann. 7-13-1001 et seq. After Anderle successfully completed the program the court held a sentence reduction hearing and reduced Anderle's sentence by two years. The Supreme Court affirmed, holding that the district court reasonably declined to reduce Anderle's sentence to probation. View "Anderle v. State" on Justia Law

Police arrested 18-year-old high school student Ismael Avalos on a murder charge and questioned him in an interrogation room at a police station. During the interview, a forensic technician removed his shirt, pants, socks, and shoes. The technician gave him a paper gown to wear. After about five hours of questioning by police, Avalos said, “I wanna talk to a lawyer.” After some further dialog, a detective said, “I respect your decision that you wanna talk to a lawyer, but if for some reason you want to change your mind and you wanna talk to me, you can, just ask for me. I don’t care if it’s 2:00, 3:00 in the morning I’ll come back. Okay? Because I care about you getting your story the right way out. Okay?” After spending the night in a holding cell, Avalos told one of the jailers he wanted to speak to the detectives again. Avalos was brought back to the same interrogation room for a second interview, still apparently wearing the same paper gown from the day before. Avalos asked, “Whatever I tell my lawyer, he’s going to tell you the same thing, right?” After waiving his Miranda rights, Avalos admitted shooting the murder victim, stating: “I, I self-defended myself, you know?” Avalos was convicted of murder with a firearm enhancement and a substantive gang crime. On appeal, Avalos contends the trial court erred by admitting the second interview into evidence over his objection. Avalos also argues that due to a recent change in the law, his substantive gang conviction must be reversed. The Court of Appeal concluded after review of the trial court record that Avalos did not make a voluntary, knowing, and intelligent Miranda waiver prior to the second interview. The Court further found the admission of the interview into evidence was not harmless beyond a reasonable doubt. The Attorney General conceded Avalos’ substantive gang conviction should have been reversed and the Court of Appeal agreed. Thus, it reversed the judgment. View "California v. Avalos" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

Petitioner Li’Anthony Williams was 17 years old in 2001 when he pleaded guilty to assault in the second degree with sexual motivation and was sentenced under the indeterminate sentencing scheme for sex offenders. The trial court imposed the statutory maximum term of life with a minimum term at the bottom of the three to nine month standard range. Williams was transferred to the Department of Corrections (DOC) with the understanding that his release date would be determined by the Indeterminate Sentence Review Board (ISRB or Board). The ISRB found Williams was not releasable. Williams in turn filed a personal restraint petition (PRP) on grounds that his maximum term of life sentence was unconstitutional and that he was sentenced to a nonexistent crime. Williams also argued his petition was not barred by the one-year time limit for two reasons: (1) his claim was based on Washington v. Houston-Sconiers, 391 P.3d 409 (2017), which was a significant, material change of law that should be retroactively applied; and (2) his conviction was invalid on its face. The Washington Supreme Court disagreed with both claims: Williams’ petition failed to meet the time bar exception under RCW 10.73.100(6) because his sentence did not violate the substantive rule of Houston-Sconiers; therefore, Houston-Sconiers was not material to Williams’ claim. Furthermore, Williams’ petition did not meet the exception under RCW 10.73.090 because the State’s failure to specify the intended felony underlying the conviction on the judgment and sentence (J&S) did not render the J&S invalid on its face. The Court therefore dismissed Williams’ petition as untimely. View "In re Pers. Restraint of Williams" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Petitioner's motion for judgment on the pleadings, entering judgment in Petitioner's favor for the relief requested in his petition, and denying the Director of the Division of Correction's motion for summary judgment, holding that the circuit court erred.Petitioner pleaded guilty to first-degree murder and aggravated assault. After the General Assembly passed the Fair Sentencing of Minors Act (FSMA), which contained parole-eligibility provisions that applied retroactively to Petitioner, Petitioner filed a petition for declaratory judgment, injunctive relief, and mandamus relief seeking to resolve any uncertainty regarding the FSMA as applied to him. The circuit court granted Petitioner's motion for judgment on the pleadings and denied the Board's motion for summary judgment, finding that Ark. Code Ann. 16-93-621(a)(2)(A) applied retroactively to Petitioner's sentences. The Supreme Court reversed, holding that the circuit court erred in its interpretation of section 16-93-621(a) and by finding that Petitioner was parole eligible after serving twenty-five years' imprisonment. View "Arkansas Parole Bd. v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions, entered upon his guilty plea, for involuntary manslaughter, having weapons while under a disability, and aggravated riot, holding that the juvenile court's probable cause determination was not subject to a manifest-weight challenge on appeal.The State filed a complaint in the juvenile court alleging that Defendant committed involuntary manslaughter and related offenses. The juvenile court determined that the State had established probable cause to believe that Defendant committed the offense and transferred Defendant's case to the general division. Defendant ultimately pled guilty. On appeal, Defendant argued that the juvenile court erred in transferring his case to the general division. The court of appeals affirmed. The Supreme Court affirmed, holding that a juvenile court's probable cause determination at a mandatory binder hearing is not subject to a manifest-weight review on appeal. View "State v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a person adjudicated a juvenile delinquent may not reopen his or her direct appeal from the adjudication based on a claim of ineffective assistance of appellate counsel under App.R. 26(B).The juvenile division of the court of common pleas adjudicated T.A. a delinquent child. The Ninth District Court of Appeals affirmed. T.A. subsequently filed an application to reopen his direct appeal under App.R. 26(B). The Ninth District denied the application, concluding that a child adjudicated delinquent may not apply for reopening of his or her appeal from the adjudication under the rule. The Supreme Court affirmed, holding that App.R. 26(B) does not apply to juvenile adjudications. View "In re T.A." on Justia Law

Kengi Moses appealed an amended order deferring imposition of sentence entered upon a conditional plea of guilty to unlawful possession of a firearm. The North Dakota Supreme Court affirmed, concluding that Moses’ prior juvenile adjudication qualified as a predicate conviction under the statute prohibiting possession of a firearm following a criminal conviction and that he received due process under the law. View "North Dakota v. Moses" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law