Justia Juvenile Law Opinion Summaries

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

The defendant was charged with several offenses, including attempted gross sexual imposition, gross sexual imposition, two counts of child neglect, and indecent exposure, based on allegations that he forced two minor children to consume Nyquil and, in one case, marijuana/THC gummies. The State alleged these actions constituted child neglect under North Dakota law. The case proceeded to a jury trial, where the defendant moved for acquittal at the close of the State’s case and again after the defense rested, but both motions were denied. The jury found the defendant guilty on the two counts of child neglect, and the district court entered judgments of acquittal on the remaining charges.The District Court of Williams County, Northwest Judicial District, presided over the trial and sentencing. On appeal to the Supreme Court of North Dakota, the defendant argued that the evidence was insufficient to support the child neglect convictions, contending that the statute criminalizes only omissions, not affirmative acts, and that his conduct, if criminal, would constitute child abuse rather than neglect. He also challenged the admission of jail call recordings, arguing improper authentication and hearsay.The Supreme Court of North Dakota held that the child neglect statute is not limited to omissions but can include affirmative acts that constitute a willful failure to provide proper parental care. The court found sufficient evidence supported the jury’s verdict and that the district court did not err in denying the motions for acquittal. Regarding the jail call recordings, the court concluded that the State provided sufficient evidence to authenticate the recordings and that the defendant’s failure to object on hearsay grounds at trial precluded reversal on that basis. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Hendricks" on Justia Law

A sixteen-year-old youth admitted to sexually assaulting his two younger half-siblings, ages six and seven, over a period spanning late 2021 to early 2023. The abuse involved coercion through threats of withholding privileges and included both physical and digital penetration. The youth was charged with multiple counts of felony sexual assault and incest, and a more serious charge was dismissed as part of a plea agreement. A psychosexual evaluation found the youth to be at moderate risk of reoffending and recommended against requiring registration as a sexual offender, suggesting that avoiding registration would better support his rehabilitation. The victims’ family members and therapist, however, advocated for registration due to the trauma suffered.The Fourth Judicial District Court, Missoula County, reviewed the psychosexual evaluation, probation officer’s report, and victim impact statements. The court designated the youth as a Level 2 Sexual Offender, committed him to a youth correctional facility until age 18, and placed him on probation until age 21. Despite recommendations against registration from the evaluator and probation officer, the court ordered the youth to register as a sexual offender for life, citing the need to protect the public given the nature of the offenses and the youth’s position of trust.On appeal, the Supreme Court of the State of Montana considered whether the District Court abused its discretion in imposing the registration requirement. The Supreme Court held that the District Court acted within its discretion, finding substantial evidence supported the decision and that the court properly considered the statutory requirements and public interest. The Supreme Court affirmed the District Court’s order requiring the youth to register as a sexual offender. View "In re B.J.B." on Justia Law

The case concerns Kenneth Robinson, who was convicted of malice murder and other offenses related to the shooting death of Devontae Jones and the aggravated assault of Charmisa Witherspoon. The evidence showed that Robinson, age fourteen at the time, was involved with the 9 Trey Bloods gang. After a gang member, Jesus Cintron, disappeared, the gang’s leader plotted to kill Witherspoon and her son, fearing Witherspoon would cooperate with law enforcement. Robinson and other gang members went to Witherspoon’s house, where Robinson participated in the assault. Witherspoon escaped, but her son was killed. Robinson was tried alongside several co-defendants.The Superior Court of Fulton County granted Robinson a directed verdict on several counts and dead docketed one count, later nol prossed. The jury found Robinson guilty on the remaining counts except one. He was sentenced to life plus forty-five consecutive years. Robinson filed a motion for new trial, which was denied. His initial appeal was dismissed due to a pending count, but after that count was nol prossed, he filed an amended notice of appeal.The Supreme Court of Georgia reviewed the case. Robinson argued that his trial counsel was ineffective for failing to communicate a plea offer, that his sentencing procedure violated constitutional and statutory rights, that the trial court misunderstood its sentencing discretion, and that certain counts should have merged for sentencing. The court held that trial counsel did communicate the plea offer, so there was no deficient performance. The court also found no constitutional or statutory violation in the sentencing procedure, noting that neither Robinson nor his counsel objected or requested to be heard. Claims regarding the trial court’s sentencing discretion and merger of counts were found to be waived or without merit. The Supreme Court of Georgia affirmed Robinson’s convictions. View "ROBINSON v. THE STATE" on Justia Law

Eric Skeens was convicted in Indiana of five counts of child molesting, based almost entirely on the detailed testimony of the child victim, K.W. There was no physical evidence presented at trial, but the prosecution relied on K.W.’s account, as well as supporting testimony from her mother, a school counselor, a therapist, and a sexual assault nurse who explained the absence of physical evidence. During closing arguments, Skeens’s attorney made a statement to the jury, “I believe her,” referring to K.W., which Skeens later argued constituted ineffective assistance of counsel.After his conviction, Skeens appealed to the Indiana Court of Appeals, which affirmed the conviction and found that the attorney’s statement did not prejudice the outcome, given the strength and detail of K.W.’s testimony. The Indiana Supreme Court declined to review the case, and Skeens’s subsequent state post-conviction and federal habeas petitions were also denied. The United States District Court for the Northern District of Indiana denied relief, concluding that Skeens had not shown the state court’s decision was unreasonable under federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case, applying the deferential standards required by the Antiterrorism and Effective Death Penalty Act and Strickland v. Washington. The court held that the Indiana Court of Appeals did not unreasonably determine the facts or unreasonably apply the Strickland standard when it concluded that there was no reasonable probability the outcome would have been different absent the attorney’s statement. The Seventh Circuit therefore affirmed the district court’s denial of Skeens’s habeas petition. View "Skeens v Neal" on Justia Law

In November 2016, D.J., then 15 years old, was involved in a marijuana transaction that resulted in the shooting death of J.S. The State charged D.J. with felony murder, aggravated robbery, and possession of marijuana. D.J. agreed to plead no contest in exchange for the case being designated as an extended jurisdiction juvenile prosecution (EJJP) rather than being tried as an adult. The court sentenced D.J. to a juvenile correctional facility until he was 22 years, 6 months old, with an adult sentence of life without parole for 25 years for the felony murder count, among other penalties, stayed as long as D.J. complied with his juvenile sentence.In October 2021, D.J. was released on conditional release but was later found in a vehicle with firearms and marijuana, and in July 2022, he was caught driving without a license and possessing marijuana. The State moved to revoke D.J.'s juvenile sentence, and the district court found that D.J. had violated the conditions of his juvenile sentence by possessing firearms and marijuana and eluding law enforcement.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the revocation of D.J.'s juvenile sentence. The court also held that under K.S.A. 38-2364, the district court was required to revoke the juvenile sentence and impose the adult sentence upon finding a violation of the juvenile sentence. The court rejected D.J.'s arguments that the district court had discretion to continue the stay of the adult sentence and that the district court could modify the adult sentence under K.S.A. 22-3716.The court also dismissed D.J.'s constitutional proportionality claims, stating that case-specific challenges could not be raised for the first time on appeal and that D.J. failed to comply with Supreme Court Rule 6.02(a)(5) for his categorical challenge. Finally, the court declined to review D.J.'s ineffective assistance of counsel claim due to the lack of a Van Cleave hearing and insufficient factual development in the record. View "In re D.J. " on Justia Law