Justia Juvenile Law Opinion Summaries

The juvenile court assumed jurisdiction over M.A. upon his admission that he had committed a felony sexual battery (Penal Code 243.4). The juvenile court granted him probation for one year. At the recommendation of the probation officer—who noted that sexual battery was among the offenses referenced in section 29805—and over M.A.’s objection, the court ordered “[t]hat [M.A.] shall immediately surrender any and all firearms … and refrain from possessing, owning, or controlling any and all firearms until his . . . 30th birthday.” Under Penal Code 29820, a minor adjudged a ward of the juvenile court for certain offenses—including “an offense enumerated in Section 29805”—shall be prohibited until age 30 from possessing firearms. Under section 29805, adults convicted of certain misdemeanors are subject to a 10-year prohibition against possessing firearms.The court of appeal affirmed the order. The prohibition against firearms for certain juvenile offenders applies to M.A. because he committed an offense that is “enumerated” in section 29850; to the extent M.A. challenged the imposition of the prohibition as a probation condition, the prohibition against firearms is statutorily authorized and required under section 29820. The term “enumerated” must be interpreted as including both felony and misdemeanor violations of the statutes listed in section 29805. View "In re M.A." on Justia Law

The State of Vermont appealed a family division court's dismissal of three juvenile delinquency petitions against S.D. for lack of subject-matter jurisdiction. The State argued the family division retained jurisdiction to transfer them to the criminal division even after S.D. reached the age of twenty years and six months. S.D. argued 13 V.S.A. § 7403 did not provide a right for the State to appeal the dismissal of a delinquency petition. The Vermont Supreme Court agreed with S.D. and dismissed this appeal, overruling precedent to the contrary in In re F.E.F., 594 A.2d 897 (1991). View "In re S.D." on Justia Law

Tonelli Anderson petitioned the Washington Supreme Court for review of his 61-year sentence he received for two first degree murders committed at age 17. Anderson asked the Court to find his sentence was unconstitutionally cruel under the Washington constitution, arguing that Washington v. Haag announced a bright line rule that no juvenile offender could ever receive a sentence of 46 years or longer, no matter how serious or numerous their crimes might be. The Supreme Court agreed that Haag limited the category of juvenile offenders who could receive a de facto life without parole (LWOP) sentence, but when the offender’s crimes do not reflect those “mitigating qualities of youth,” Washington’s constitution does not bar a de facto LWOP sentence. In light of the evidence presented at trial, the Supreme Court concluded the trial court appropriately determined Anderson’s crimes did not reflect “youthful immaturity, impetuosity, or failure to appreciate risks and consequences.” Therefore his sentence was affirmed. View "Washington v. Anderson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of the parole board as to Plaintiff's appeal from the board's fourth denial of his request for parole, holding that the superior court correctly affirmed the board's decision to deny Plaintiff release on parole.After a retrial, Plaintiff was convicted of rape and assault and battery by means of a dangerous weapon for crimes he committed when he was sixteen years old. He was sentenced to life imprisonment with the possibility of parole. In denying Plaintiff's fourth request for parole, the board concluded that he was not yet rehabilitated and that his release was not compatible with the welfare of society. The superior court affirmed. The Supreme Judicial Court affirmed, holding that Plaintiff was not entitled to relief as to any of his arguments on appeal. View "Rodriguez v. Mass. Parole Board" on Justia Law

Petitioner Devin Miles sought certiorari review of superior court decisions denying his motion to quash an indictment against him, his renewed motion to quash, his motion for interlocutory appeal, and his motion for findings of fact and rulings of law. In August 2019, the State filed three juvenile delinquency petitions against petitioner in the family division of the circuit court. One of the juvenile petitions charged the petitioner with a pattern of aggravated felonious sexual assault (AFSA). Petitioner argued the court erred by failing to quash the indictment because, in his view, the indictment was contrary to RSA 169-B:4, VII (Supp. 2021) and violated New Hampshire Rule of Criminal Procedure 20(a)(4) as well as his double jeopardy rights pursuant to the State and Federal Constitutions. Finding no reversible error, the New Hampshire Supreme Court affirmed the superior court. View "Petition of Devin Miles" on Justia Law

Child, then age seventeen, became Facebook friends with a former schoolmate, Jeremiah Erickson (Erickson), then age nineteen. The two conversed primarily through their respective Facebook Messenger accounts. Child and Erickson used Messenger to arrange in-person meetings, during which Erickson drove to Child’s house to pick her up and drive her somewhere to “hang out.” It was the second of these meetings that gave rise to the events leading to Child’s adjudication. Both Erickson and Child testified that their get-together on the night of February 24, 2020, did not end well, and each provided a different narrative as to what unfolded. At Child’s adjudication, the State sought to introduce evidence of communications between Child and Erickson the State alleged took place on Facebook Messenger the day after an incident involving Erickson’s vehicle. The State sought to authenticate the messages through Erickson’s testimony as to his personal knowledge of both the accuracy of screenshots and his history of Facebook Messenger communications with Child, as well as through the contents of the messages themselves. Child’s counsel objected to the authentication of the exhibits, arguing the screenshots did not show with certainty the messages were sent from Child’s Facebook account and emphasizing what counsel characterized as the inherent difficulty in “lay[ing a] foundation on Facebook Messenger messages because anybody can have access to somebody’s phone or Facebook account.” The district court overruled the objection, and the evidence was admitted. Child was subsequently adjudicated delinquent and appealed the district court’s judgment and disposition. The New Mexico Supreme Court agreed with the Court of Appeals that the traditional authentication standard set out in Rule 11-901 provided the appropriate legal framework for authenticating social media evidence. But the Court disagreed with appellate court's conclusion that the State failed to meet the threshold for authentication established under that rule, much less that the district court abused its discretion in finding the State had met its burden. The Supreme Court held the State’s authentication showing was sufficient under Rule 11-901 to support a finding that, more likely than not, the Facebook Messenger account used to send the messages belonged to Child and that Child was the author of the messages. Accordingly, the Court of Appeals was reversed and Child’s delinquency adjudications were reinstated. View "New Mexico v. Jesenya O." on Justia Law

The Supreme Judicial Court held that under the plain language of Mass. Gen. Laws ch. 119, 68 a juvenile defendant who is charged with murder and a properly-joined nonmurder offense must be committed to the custody of the sheriff if the defendant is not released on bail.Defendant, who was sixteen years old at the time of the offense, was charged with murder in the first degree and armed assault with intent to rob. At issue was whether the superior court judge had discretion to craft a bail order releasing Defendant on personal recognizance on the murder charge and ordering him to be held without bail on the related nonmurder charge such that he may continue to be held by the Department of Youth Services after his eighteenth birthday. The superior court judge concluded that he lacked the discretion to craft such a bail order and committed Defendant to the custody of the sheriff under Mass. Gen. Laws ch. 119, 68. The Supreme Judicial Court affirmed, holding that that plain language of the statute required that the superior court judge commit Defendant to the custody of the sheriff. View "Nicholas-Taylor v. Commonwealth" on Justia Law

In August 2019, the State of New Hampshire filed three juvenile delinquency petitions against Respondent in the family division, charging him with one count of pattern aggravated felonious sexual assault (AFSA), one count of felonious sexual assault, and one count of indecent exposure. The AFSA petition alleged that the acts comprising the pattern offense occurred on four specific dates: June 22, 2018; August 24, 2018; September 15, 2018; and May 27, 2019. When the petitions were filed, the alleged victim was six years old and Respondent was seventeen years old. Respondent turned eighteen in November 2019 and at the time of this appeal was twenty years old. After filing the petitions, the State, pursuant to RSA 169-B:24, petitioned to certify Respondent as an adult and transfer the case to superior court. This petition was denied and the New Hampshire Supreme Court accepted the State’s Rule 11 petition to determine whether the superior court erred in denying the State’s petition to certify Respondent as an adult. Finding the superior court so erred, the Supreme Court reversed and remanded. View "Petition of State of New Hampshire" on Justia Law

Petitioner Antoine Davis was 21 when he was convicted of first degree murder and second degree attempted murder. He received a standard range sentence of 767 months. Davis filed this personal restraint petition (PRP) more than one year after his judgment and sentence finalized, contending it was. timely for two reasons: (1) In re Personal Restraint of Monschke, 482 P.3d 276 (2021) constituted a significant, material, and retroactive change in law that applied to his de facto life sentence; and (2) recent advances in neuroscience for late-aged adolescents qualified as newly discovered evidence. The Washington Supreme Court found: (1) Monschke applied to 19- and 20-year-old defendants; and (2) Davis did not satisfy any of the statutory criteria that exempted his petition from the one-year time bar. View "In re Pers. Restraint of Davis" on Justia Law

Kemo Parks was convicted by jury for first-degree premeditated-murder. Parks was 18 years old when he aided and abetted in the murder. Parks argued that his sentence was cruel and/or unusual punishment under both the United States and Michigan Constitutions. Under current United States Supreme Court precedent, the Michigan Supreme Court concluded Parks’s Eighth Amendment argument failed. However, the Court held his sentence of mandatory life without parole violated the Michigan Constitution’s ban on “cruel or unusual” punishment. Specifically, his sentence lacked proportionality because it failed to take into account the mitigating characteristics of youth, specifically late-adolescent brain development. Therefore, the Supreme Court reversed the portion of the judgment of the Court of Appeals affirming Parks’s sentence, vacated Parks’s life-without-parole sentence, and remanded this case to the Circuit Court for resentencing proceedings. View "Michigan v. Parks" on Justia Law