Justia Juvenile Law Opinion Summaries

Niquan M. Dunn was indicted on six counts in the Geauga County Common Pleas Court, including drug-related crimes and possession of criminal tools. Counts 2 and 4, relevant to this appeal, charged Dunn with aggravated trafficking in drugs and trafficking in cocaine, respectively, with enhancements for committing the crimes "in the vicinity of a juvenile." The case proceeded to trial, where the State presented evidence including testimony from detectives and a controlled buy operation. Drugs and drug paraphernalia were found in a house where Dunn was staying, and a four-month-old child was present in the home.The trial court denied Dunn's motion for acquittal on Counts 1 through 5 and the jury found him guilty on those counts. Dunn was sentenced to a total of 36 months in prison. On appeal, the Eleventh District Court of Appeals reversed the convictions in part, finding insufficient evidence that Dunn committed the crimes in the vicinity of a juvenile, as required for the enhancement. The appellate court focused on the lack of direct evidence that the child was present during the drug activities and distinguished the case from prior decisions.The Supreme Court of Ohio reviewed the case and held that the evidence was sufficient to support the "in the vicinity of a juvenile" enhancement. The court emphasized that circumstantial evidence and reasonable inferences drawn from the evidence could lead a reasonable juror to conclude that the child was present when Dunn prepared the drugs for distribution. The court reversed the Eleventh District's judgment, reinstating the enhancement on Count 2. View "State v. Dunn" on Justia Law

Santiago Gonzalo Canales was convicted of lewd acts and continuous sexual abuse of children, specifically his stepdaughter and niece, both under the age of 14 during the abuse. Canales's niece testified that he molested her from ages seven to 13, while his stepdaughter testified that he began molesting her when she was about 11, including vaginal penetration. Canales denied all allegations.The Superior Court of Los Angeles County convicted Canales on all counts and found true the multiple victims allegations. He was sentenced to 60 years to life in prison, consisting of four consecutive sentences of 15 years to life.The California Court of Appeal, Second Appellate District, reviewed the case. Canales challenged two jury instructions: CALCRIM No. 1120 and CALCRIM No. 252. The court upheld the use of CALCRIM No. 1120, stating it correctly reflected the statutory requirements for continuous sexual abuse, which did not necessitate a heightened mental state for "substantial sexual conduct." The court acknowledged an error in CALCRIM No. 252 but deemed it harmless beyond a reasonable doubt due to the overwhelming evidence of Canales's guilt. Canales's argument regarding the unanimity instruction was forfeited as he did not raise it during the trial.The court agreed with Canales and the prosecution that his sentence violated ex post facto principles because the One Strike law, which enhanced his sentence, did not apply to his offenses against his stepdaughter, which occurred before the law was amended to include continuous sexual abuse. Consequently, the court vacated Canales's sentence and remanded the case for resentencing without applying the One Strike law. View "People v. Canales" on Justia Law

A juvenile was seen masturbating in a parked car and was charged with open and gross lewdness and lascivious behavior, a felony. At trial, the jury was also instructed on the lesser included offense of indecent exposure, a misdemeanor punishable by no more than six months in jail. The jury found the juvenile delinquent only of the lesser included offense. The juvenile, who had no prior offenses, argued that the delinquency adjudication must be dismissed for lack of subject matter jurisdiction.The Juvenile Court judge denied the motion to dismiss and sentenced the juvenile to a continuance without a finding until his nineteenth birthday, after which the charge was dismissed. The juvenile appealed, and the Supreme Judicial Court transferred the case from the Appeals Court to address whether the Juvenile Court retained jurisdiction over a first offense of a minor misdemeanor after a jury trial.The Supreme Judicial Court concluded that once the jury found the juvenile delinquent only of a minor misdemeanor and it was undisputed that it was his first offense, the Juvenile Court no longer had subject matter jurisdiction. The court held that the delinquency adjudication should have been dismissed and recorded only as a Wallace W. determination. The court vacated the adjudication of delinquency and remanded the matter to the Juvenile Court with instructions to make the appropriate entry. View "Commonwealth v. Vince V." on Justia Law

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also contended the trial court had jurisdiction to resentence Bagsby and erred by ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed section 1170(d) despite amendments and that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and outside juvenile court jurisdiction. The court also found the stay order would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. View "P. v. Bagsby" on Justia Law

In May 2019, a fire in Davisville resulted in the deaths of Robert and Charlotte Taylor and injuries to a child. Sixteen-year-old M.W., the Taylors' daughter, was interviewed by Deputy Fire Marshal Jason Baltic at the scene. During the interview, M.W. confessed to starting the fire using gasoline. M.W. was subsequently indicted for first-degree murder, attempted murder, and arson. She moved to suppress her confession, arguing that she had not voluntarily waived her Miranda rights and that her confession was coerced. The circuit court denied the motion, and the case proceeded to trial, where the jury found M.W. guilty on all counts.The Circuit Court of Wood County denied M.W.'s motion to suppress her confession, finding that she had knowingly, intelligently, and voluntarily waived her Miranda rights. The court also found that her confession was not coerced. M.W. later filed an emergency motion to reconsider the suppression ruling, citing a Brady violation due to the late disclosure of Deputy Sheriff Tasha Hewitt's past untruthfulness. The circuit court denied this motion, stating that Baltic's testimony was credible and sufficient to establish that M.W. had been read her Miranda rights.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the circuit court's decisions. The court held that M.W. had knowingly, intelligently, and voluntarily waived her Miranda rights, considering her age, intelligence, and the circumstances of the interview. The court also found that her confession was not coerced, as Baltic's interview techniques did not overbear her will. Additionally, the court ruled that the late disclosure of Hewitt's past untruthfulness did not constitute a Brady violation that would have changed the outcome of the suppression hearing. Finally, the court upheld the jury's verdict, finding sufficient evidence to support M.W.'s convictions. View "State v. M.W." on Justia Law

In this case, the defendant was accused of sexually assaulting three minors between 2007 and 2009. The police obtained a search warrant and found child pornography on the defendant's computers, including an encrypted file they could not access. The defendant was indicted on multiple counts, including sexual conduct against a child and possession of child pornography. He posted bail and was released but was later remanded to jail for allegedly posting a blog that intimidated a witness.The trial court assigned counsel and experts to assist the defendant, who later chose to represent himself. During the trial, the defendant's daughter testified about a recorded conversation in which one of the victims allegedly recanted her accusations. The prosecution used recorded jail phone calls to challenge the daughter's testimony, revealing that the defendant had discussed trial strategies with her. The jury found the defendant guilty of one count of sexual conduct against a child and all child pornography counts but deadlocked on other charges. The defendant entered an Alford plea to the deadlocked counts.The Appellate Division affirmed the judgment, and the New York Court of Appeals reviewed the case. The primary issue was whether the defendant's right to present a defense was violated by the prosecution's monitoring of his jail phone calls. The Court of Appeals held that the defendant's right to present a defense was not violated. The court noted that the defendant had ample time to prepare his defense while out on bail and had other means to communicate with witnesses. The court also found that the defendant's request to proceed pro se was unequivocal and that the trial court had conducted a proper inquiry into the risks of self-representation. The order of the Appellate Division was affirmed. View "People v Dixon" on Justia Law

G.W. was convicted of simple assault in 2019 after allegedly grabbing the jacket of a Metropolitan Transit Police Department officer outside the Anacostia Metro Station. G.W. filed a notice of appeal, and the case was remanded to allow the trial court to set aside his conviction under the Youth Rehabilitation Act (YRA). Following the trial court's set-aside order and issuance of a new judgment and commitment order, G.W. filed a new notice of appeal, challenging his conviction.The Superior Court of the District of Columbia initially convicted G.W. of simple assault. G.W. timely filed a notice of appeal, and the case was stayed pending the outcome of the en banc decision in Perez Hernandez v. United States, which addressed the elements of an offensive touching assault. After the decision in Perez Hernandez, the stay was lifted, and G.W. sought an indicative ruling for a YRA set-aside. The trial court issued an indicative set-aside order, and the case was remanded. The trial court then issued a set-aside order and an amended judgment and commitment order, which G.W. appealed.The District of Columbia Court of Appeals reviewed the case and concluded that G.W.'s appeal was properly before the court. The court determined that the trial court had not applied the correct elements of an offensive touching assault as defined in Perez Hernandez. Specifically, the trial court did not consider whether G.W.'s actions would offend a person's reasonable sense of personal dignity and whether G.W. acted with the purpose of causing offense or knowing that his actions would cause offense. The court vacated the judgment and remanded the case for the trial court to make the necessary findings regarding G.W.'s mens rea and the nature of the touch. The court did not reach G.W.'s Rule 16 claim due to the decision to remand. View "G.W. v. United States" on Justia Law

Christopher Segerstrom was convicted of capital murder for the 1986 killing of a four-year-old and was initially sentenced to life imprisonment without parole. He was 15 years old at the time of the crime. Following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibits mandatory life without parole for juvenile offenders, Segerstrom's sentence was vacated and remanded for resentencing. The Washington County Circuit Court resentenced him to life with the possibility of parole after thirty years without a hearing, which was reversed by the Arkansas Supreme Court, mandating a hearing to consider mitigating factors.Upon remand, Segerstrom's fitness to proceed was contested. The circuit court initially found him unfit due to schizophrenia but later deemed him fit after a year of treatment, based on a forensic evaluation by Dr. Melissa Wright. Segerstrom's defense presented conflicting expert testimony, but the court credited Dr. Wright's findings. On the day of the resentencing hearing, Segerstrom's counsel requested a continuance, claiming he was unresponsive due to medication, which the court denied.During the resentencing, the court admitted prior testimony from Dr. Joseph Halka, who performed the autopsy, over Segerstrom's objection. The court also rejected a nonmodel jury instruction proposed by Segerstrom, which emphasized the differences between juvenile and adult offenders as per Miller. The jury ultimately sentenced Segerstrom to life imprisonment.The Arkansas Supreme Court affirmed the circuit court's decisions, holding that substantial evidence supported the finding of Segerstrom's fitness to proceed, the denial of the continuance was not an abuse of discretion, the admission of Dr. Halka's testimony was proper, and the rejection of the proposed jury instruction was appropriate given the sentencing options. View "SEGERSTROM V. STATE OF ARKANSAS" on Justia Law

In 2018 and 2019, a minor, J.S., committed a series of serious crimes, including seven street robberies, two burglaries, an attempted robbery resulting in murder, and the drugging and sexual assault of a 14-year-old girl. J.S. was 16 and 17 years old at the time of these offenses. The People filed an 18-count petition against J.S., including charges of murder, robbery, burglary, and sexual assault, and sought to transfer him to adult criminal court.The juvenile court in Ventura County conducted a transfer hearing and found that J.S. was not amenable to rehabilitation within the juvenile system's jurisdiction, which would expire when he turned 25. The court considered J.S.'s criminal sophistication, previous delinquent history, and the gravity of the offenses. Despite evidence of J.S.'s participation in rehabilitation programs and expert testimony suggesting potential for rehabilitation, the court concluded that the severity and premeditated nature of his crimes, along with his behavior in custody, indicated a need for prolonged treatment and supervision beyond the juvenile system's capacity.The California Court of Appeal, Second Appellate District, Division Six, reviewed the juvenile court's decision for abuse of discretion. The appellate court affirmed the transfer order, agreeing that substantial evidence supported the juvenile court's findings. The appellate court emphasized that it does not reweigh evidence or substitute its discretion for that of the trial court. The court found that the juvenile court had appropriately considered the statutory criteria and expert testimony, and its conclusion that J.S. was not amenable to rehabilitation within the juvenile system was supported by clear and convincing evidence. View "People v. J.S." on Justia Law

Fifteen-year-old Bjorn Harris was arrested on April 30, 2023, for murder and other charges related to the shooting death of Jaylan Major. He was detained at the Regional Metro Youth Detention Facility. On May 5, 2023, the Superior Court of Fulton County found probable cause for the charges, appointed counsel for Harris, and denied bond. Harris was indicted on July 28, 2023, for voluntary manslaughter, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony. On November 16, 2023, he was reindicted for murder, felony murder, and additional charges. The initial indictment was nolle prossed on November 21, 2023.Harris filed a motion on December 1, 2023, to transfer his case to juvenile court, arguing that the State failed to indict him within 180 days as required by OCGA § 17-7-50.1. The Superior Court held a hearing on December 7, 2023, and granted the motion on December 11, 2023, relying on the Court of Appeals' decision in State v. Armendariz. The court concluded that the reindictment outside the 180-day period necessitated the transfer to juvenile court.The Supreme Court of Georgia reviewed the case and reversed the Superior Court's decision. The Supreme Court held that OCGA § 17-7-50.1 requires a grand jury to return a true bill of indictment within 180 days of detention, which was met with the July 2023 indictment. The statute does not prohibit reindictment outside the 180-day period. Therefore, the Superior Court retained jurisdiction, and the transfer to juvenile court was not authorized. The Supreme Court clarified that the timely return of a true bill on any charge within the superior court's jurisdiction suffices to retain jurisdiction, regardless of subsequent reindictments. View "THE STATE v. HARRIS" on Justia Law