Justia Juvenile Law Opinion Summaries

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

A deadly shooting occurred at a house party in Las Cruces, New Mexico, in July 2021. During a chaotic altercation, multiple gunshots were fired, resulting in the death of Nicodemus Gonzales and damage to a vehicle driven by Jayissa Borrunda. Eyewitnesses described seeing the defendant and his cousin brandishing guns with laser sights. Forensic evidence was inconclusive as to which weapon caused the fatal injury. The defendant, who was seventeen at the time, was charged as a Serious Youthful Offender with first-degree (willful and deliberate) murder and other related offenses.The District Court of Doña Ana County acquitted the defendant of first-degree (willful and deliberate) murder but allowed the case to proceed to the jury on first-degree felony murder, predicated on aggravated assault, as well as other charges. The jury convicted the defendant of first-degree felony murder (as an accomplice to aggravated assault), aggravated assault, two counts of conspiracy, and shooting at a motor vehicle. The court imposed a thirty-year sentence for felony murder, an enhanced sentence for aggravated assault, and additional concurrent sentences for the other convictions.The Supreme Court of the State of New Mexico reviewed the case. It held that aggravated assault is a noncollateral felony and cannot serve as the predicate for felony murder; therefore, the defendant’s felony murder conviction must be vacated as a legal nullity. The Court further held that double jeopardy does not bar retrial for felony murder or its lesser-included offenses when a conviction is reversed for a nonexistent crime, as this constitutes trial error rather than an acquittal. The Court also vacated one conspiracy conviction for lack of evidentiary support and reversed the four-year firearm enhancement as unauthorized by statute. The remaining convictions were affirmed, and the case was remanded for further proceedings consistent with the opinion. View "State v. Revels" on Justia Law

A group of teenagers and young adults devised a plan to rob and murder a man, Justin McKinney, and his girlfriend, Anna Franklin, as revenge for a drug-related incident involving one of the conspirators’ brothers. On the night of the crime, several of the group entered the victims’ home, where one participant shot and killed McKinney, and another shot and wounded Franklin. The group then fled, disposed of weapons, and made incriminating statements. Franklin survived and identified some of the assailants. Physical evidence, including firearms and shell casings, corroborated the events described by witnesses and participants.After the incident, several co-defendants pleaded guilty, while one was tried separately. The appellant, who was a juvenile at the time, was tried by a jury in the Superior Court of Fannin County and found guilty on all counts, including malice murder, attempted murder, and related offenses. He was sentenced to life in prison plus additional consecutive and concurrent terms. The trial court denied his motion for a new trial.The Supreme Court of Georgia reviewed the case. The appellant argued that his custodial statements should have been suppressed due to his age, learning disability, and other factors; that the trial court erred by modifying a pattern jury instruction to include “age” as a factor not to influence the jury; and that a post-incision autopsy photograph was improperly admitted. The Supreme Court of Georgia held that the trial court did not err in admitting the custodial statements, as the totality of the circumstances showed a knowing and voluntary waiver of rights. The Court also found no plain error in the jury instruction and no abuse of discretion in admitting the autopsy photograph. The convictions and sentences were affirmed. View "Hill v. State" on Justia Law

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

A juvenile, K.I.B., was adjudicated delinquent in June 2024 by the Juvenile Court of Burleigh County, South Central Judicial District, for promoting a sexual performance by a minor and possession of prohibited materials, both felonies under North Dakota law, as well as giving false information to law enforcement. In January 2025, the court held a hearing to determine whether K.I.B. was required to register as a sexual offender. The court found that K.I.B. had no prior sexual offender offenses and did not exhibit mental abnormality or predatory conduct during the commission of the offenses, and therefore exempted K.I.B. from the registration requirement.The State appealed the exemption order to the Supreme Court of North Dakota, arguing that the juvenile court erred in interpreting its discretion under N.D.C.C. § 12.1-32-15. The State asserted its standing to appeal based on statutory language and public safety interests. The Supreme Court reviewed the statutory interpretation de novo, focusing on whether the juvenile court had discretion to exempt K.I.B. from registration under the relevant statute.The Supreme Court of North Dakota held that N.D.C.C. § 12.1-32-15(2)(a) mandates registration for individuals adjudicated as felonious sexual offenders, including juveniles, unless the offense falls under a specific exception listed in subdivision (c), which did not apply to K.I.B. The court concluded that the juvenile court misapplied the law and abused its discretion by exempting K.I.B. from registration. The Supreme Court reversed the juvenile court’s order and remanded the case for entry of judgment consistent with its opinion, requiring K.I.B. to register as a sexual offender. View "Interest of K.I.B." on Justia Law

Police received reports of a group committing robberies or attempted robberies in a white Nissan Rogue that had been reported stolen. Officers tracked the vehicle, observed it being driven recklessly, and saw it crash. Four individuals, including E.A., fled from the car. E.A. was apprehended shortly after the crash, frisked, and found to have a handgun in his sweatshirt pocket. He was subsequently charged with carrying a pistol without a license and possession of an unregistered firearm.The Superior Court of the District of Columbia denied E.A.’s motion to suppress the handgun, finding that officers had reasonable articulable suspicion to stop and frisk him based on his association with the group suspected of recent robberies and the stolen vehicle, as well as his flight from the crash. The court also concluded that, even if the officers’ actions exceeded the scope of a Terry stop, they had probable cause to arrest E.A. for multiple offenses, justifying a search incident to arrest. E.A. was adjudicated delinquent on both firearms charges and appealed, challenging the denial of his suppression motion.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the officers had reasonable articulable suspicion to stop and frisk E.A., relying on the collective knowledge from radio dispatches, corroborated by officers’ observations and the circumstances of the stop. The court further held that the officers’ use of handcuffs and drawn weapons did not convert the stop into an arrest, given the safety concerns and flight risk. Therefore, the search and seizure of the handgun did not violate the Fourth Amendment, and the judgment was affirmed. View "In re E.A." on Justia Law

In this case, a juvenile defendant was implicated in a home invasion and rape that occurred in Methuen, Massachusetts, in November 2018. The victim identified three intruders, and subsequent investigation led to the defendant’s arrest. After his arrest, police obtained a DNA sample from the defendant via a warrantless buccal swab, which the Commonwealth later conceded was unlawful. The resulting DNA evidence was suppressed. However, after the defendant was indicted as a youthful offender, the Commonwealth, relying on evidence independent of the suppressed DNA, successfully moved for a court order compelling a second, postindictment buccal swab. DNA evidence from this second swab was admitted at trial.The Essex County Division of the Juvenile Court Department initially heard the case. The judge suppressed the first DNA sample but granted the Commonwealth’s motion to compel the second sample, finding probable cause based on evidence unrelated to the initial, unlawful swab. At trial, the defendant was convicted by a jury of aggravated rape and other offenses. He was sentenced to a term of imprisonment and probation. The defendant appealed, challenging both the order compelling the second DNA sample and the jury instructions regarding “serious bodily injury” as an element of aggravated rape. The Supreme Judicial Court of Massachusetts transferred the case from the Appeals Court for review.The Supreme Judicial Court of Massachusetts held that the second, court-ordered buccal swab was lawfully obtained based on independent probable cause and was not tainted by the prior illegality, so the DNA evidence was properly admitted. The Court also found no error in the jury instructions. However, because the general verdict did not specify which aggravating theory the jury relied on, and only one theory was supported by sufficient evidence, the aggravated rape conviction was vacated and the case remanded for further proceedings. View "Commonwealth v. Carvajal" on Justia Law

A 17-year-old defendant was charged with ten serious offenses, including murder and assault, after a violent confrontation at the home of his rivals. The incident stemmed from a feud with a classmate and escalated when the defendant, accompanied by his family, armed himself and attacked the victims’ home. The attack resulted in the death of one individual and severe injuries to others. The defendant, an enrolled member of the Cherokee Nation, was charged under federal law for crimes committed within the Cherokee Nation Indian Reservation.The United States District Court for the Eastern District of Oklahoma first reviewed the case. The government moved to transfer the defendant from juvenile to adult criminal proceedings under the Juvenile Justice and Delinquency Prevention Act. After an evidentiary hearing, the magistrate judge recommended granting the transfer, and the district court adopted this recommendation after conducting a de novo review. The district court weighed the statutory factors, including the defendant’s age, social background, psychological maturity, prior delinquency record, past treatment efforts, and the availability of rehabilitative programs, and found that most factors favored transfer to adult status.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court did not abuse its discretion in weighing the statutory transfer factors and found no clear error in its factual findings. The court also rejected the defendant’s Eighth Amendment argument that transfer was unconstitutional due to the potential punishments, holding that the challenge was unripe under circuit precedent. The Tenth Circuit affirmed the district court’s order transferring the defendant to adult criminal proceedings. View "United States v. J.D.V., Jr." on Justia Law

The defendant was convicted of eight sex crimes involving three juvenile girls, including his stepdaughter and two other children in the household. The most serious incident occurred in December 2016, when a six-year-old girl suffered a severe vaginal injury while in the defendant’s care, leading to hospitalization and subsequent disclosure of sexual abuse. Over the following years, two other girls reported that the defendant had also sexually abused them on multiple occasions, with one describing repeated acts of molestation occurring regularly over a period of time.The Sonoma County Superior Court jury found the defendant guilty on all counts, including multiple counts of sexual intercourse or lewd acts with a child under 14, and found true several sentencing enhancements. The defendant appealed, challenging two of the convictions related to one victim. He argued that the prosecution relied on the same testimony to support both charged and uncharged offenses, and that the jury instruction regarding uncharged sex offenses (CALCRIM No. 1191A) improperly lowered the prosecution’s burden of proof and confused the jury. He also raised an alternative claim of ineffective assistance of counsel for failing to object to the instruction.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that, although the same testimony was used to support both charged and uncharged offenses and the instructions could have been clearer, any potential instructional error was harmless beyond a reasonable doubt. The court found that the jury was properly instructed that each charged offense had to be proven beyond a reasonable doubt, and that the evidence supporting the convictions was substantial. The judgment of conviction was affirmed. View "People v. Dejesus-Galindo" on Justia Law

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law