Justia Juvenile Law Opinion Summaries

After Appellant Cameron Moon was certified in juvenile court to stand trial as an adult, the juvenile court ordered his case transferred to the district court for adult criminal proceedings. Appellant then filed a pretrial application of writ of habeas corpus challenging the transfer. The district court denied relief, so Appellant took an interlocutory appeal. The Court of Appeals reversed the district court’s order denying relief, concluding the State had failed to establish the necessary statutory criteria for waiver of juvenile jurisdiction and transfer into the adult criminal court. As a result, the appellate court remanded the case with instructions to dismiss the prosecution for lack of jurisdiction. The Texas Court of Criminal Appeals granted the State's petition for discretionary review to consider several issues related to the juvenile court's transfer order including whether the court of appeals erred to hold that such a challenge was even cognizable in pretrial habeas. However, the Court concluded that, even if Appellant’s claims were cognizable in a pretrial habeas proceeding, the court of appeals lacked the authority to entertain Appellant’s interlocutory appeal. Accordingly, the Court of Criminal Appeals reversed the court of appeals’ judgment and remanded to that court for an order dismissing Appellant’s appeal as premature. View "Ex parte Moon" on Justia Law

After defense counsel raised concerns regarding seventeen-year-old A.T.C.’s competency, the magistrate ordered a competency evaluation. A psychologist from the Office of Behavioral Health (“OBH”) subsequently evaluated A.T.C. and determined that he was incompetent but restorable. Shortly thereafter, based on OBH’s evaluation, the magistrate entered a preliminary finding that A.T.C. was incompetent but restorable. The State moved for a second competency evaluation, asking the magistrate to allow a psychologist of the State's choosing to evaluate A.T.C. Over defense counsel’s objection, the magistrate granted the motion. The psychologist retained by the State evaluated A.T.C. and concluded that he was competent to proceed. Following a contested hearing at which OBH’s psychologist, the psychologist retained by the State, and a third psychologist all testified, the magistrate found that A.T.C. was competent to proceed. Defense counsel timely petitioned the juvenile court for review, but was unsuccessful. Counsel then petitioned the Colorado Supreme Court. Addressing whether a juvenile in a delinquency case could seek interlocutory review of a magistrate’s competency finding in the juvenile court as a matter of first impression, the Supreme Court concluded a magistrate’s finding of competency pursuant to section 19-1-108(3)(a.5), C.R.S. (2022), was subject to review in the juvenile court under section 19-1-108(5.5). View "Colorado in the interest of: A.T.C." on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

G.C. brings this interlocutory appeal from a family division order denying his request for youthful-offender status. The State charged youth with felony sexual assault in October 2021. On appeal, G.C. argued the evidence did not support the court’s finding that there was insufficient time to meet youth’s treatment and rehabilitation needs. After review of the family division order, the Vermont Supreme Court found no reversible error and affirmed. View "In re G.C." on Justia Law

In May 2022, the juvenile court granted a motion to transfer defendant minor T.A. from juvenile court to a court of criminal jurisdiction. T.A. argued the Court of Appeal should remand so the juvenile court could reconsider its ruling in light of recent ameliorative changes to the law enacted by Assembly Bill No. 2361 (2021-2022 Reg. Sess.). The State conceded that the changes applied retroactively to a minor, like T.A., whose case was not final when they took effect. Nevertheless, the State argued, no remand was necessary here because there was no reasonable probability the juvenile court would have reached a different result under the amended law. To this, the Court of Appeal agreed and therefore affirmed. View "In re T.A." on Justia Law

Minor S.S. (minor) appealed an order transferring him from the juvenile court to a court of criminal jurisdiction, pursuant to former Welfare and Institutions Code section 707.1. Minor contended: (1) the juvenile court’s findings were not supported by substantial evidence; and (2) subsequent legislation applies retroactively and requires reversal because the juvenile court did not comply with new requirements for transfer hearings. The State conceded the second argument. The Court of Appeal agreed with the parties that the new law applied retroactively and therefore reversal and remand was appropriate for an amenability hearing in compliance with the new law. View "In re S.S." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

A juvenile wardship petition alleged against E.P. alleged two counts of murder, two counts of  attempted murder, and one count of street terrorism. The juvenile court held a fitness hearing pursuant to Welfare and Institutions Code1 section 707. The court ordered the case transferred to criminal court. Since the hearing, section 707 has been amended.   The Second Appellate District reversed and remanded for a new fitness hearing pursuant to section 707 as amended. The court explained that the amended section 707 requires the juvenile court to consider all five factors together in determining whether the minor is amenable to rehabilitation. Under the amended statute, like the previous version, the court has the discretion to conclude that one or more of the five factors predominate so as to determine the result, even though some or all of the other factors might point to a different result. The prosecution is entitled to a new fitness hearing so that the court can determine, considering all five factors, whether E.P. is amenable to treatment. View "In re E.P." on Justia Law

The Supreme Court reversed the ruling of the family court that the prosecution had proven that DM, a minor who stabbed another minor, had committed attempted assault in the first degree beyond a reasonable doubt, holding that the family court inadequately assessed the circumstances from DM's perspective in rejecting DM's self-defense defense.After a bench trial, during which DM argued that he lacked intent and acted in self-defense, the family court adjudicated DM as having committed attempted assault in the first degree. DM appealed, challenging the court's self-defense-related findings and conclusions. The Supreme Court reversed, holding (1) the family court wrongly rejected DM's defense by inadequately assessing his conduct from his perspective and by misapplying key self-defense elements; and (2) there was not substantial evidence to support the family court's conclusion that the State proved beyond a reasonable doubt that DM's use of deadly force was unjustified. View "In re DM" on Justia Law

Defendant My Ngo was a “shotcaller” in a Vietnamese gang. At age 19, he was paid $2,000 to commit a murder for hire. In 2021, he filed a motion for a “Franklin hearing”: a hearing pursuant to People v. Franklin, 63 Cal.4th 261 (2016), for a juvenile offender to preserve evidence of youth-related mitigating factors for purposes of a youthful offender parole hearing to be held in the future pursuant to Penal Code section 3051.2 Under section 3051, juvenile offenders and most youthful offenders were entitled to a youthful offender parole hearing; however, youthful offenders sentenced to life without parole (LWOP) were not. Defendant was a youthful offender sentenced to LWOP, and the trial court ruled that he was not entitled to a Franklin hearing. Defendant contended that section 3051’s distinction between youthful offenders with LWOP and non-LWOP sentences violated equal protection. Alternatively, he contended he should have been granted a hearing to preserve evidence of youth-related mitigating factors for other purposes, such as a hypothetical future resentencing under section 1172.1. The Court of Appeals disagreed with both contentions and affirmed the trial court's decision. View "California v. Ngo" on Justia Law