Justia Juvenile Law Opinion Summaries

Jones was a juvenile in 2000 when he pled guilty to first-degree murder and was sentenced to 50 years in prison pursuant to a fully negotiated plea agreement. After unsuccessfully petitioning for postconviction relief, Jones sought leave to file a successive postconviction petition alleging his sentence violated the eighth amendment protections in the Supreme Court’s “Miller v. Alabama” decision.The appellate court affirmed the denial of his motion, finding that Jones’ claims did not invoke the protections provided to juveniles in Miller. The Illinois Supreme Court affirmed. Miller’s additional protections for juvenile offenders apply only when a trial court lacks or refuses to use discretion in sentencing a juvenile offender to life, or to a de facto life, sentence. The mandatory sentencing scheme that applied in Illinois at the time he was sentenced was never applied to Jones. By entering a plea agreement, a defendant forecloses any claim of error. A voluntary guilty plea waives all non-jurisdictional errors or irregularities, including constitutional ones. Jones has not claimed that the state engaged in any misrepresentation or committed any misconduct. View "People v. Jones" on Justia Law

Defendant Allen Benzler was sentenced in 2014 for offenses he committed when he was 18 years old. He appealed the summary denial of his motion for a "Franklin" hearing under California Penal Code section 1203.01, contending he satisfied the eligibility criteria for such a hearing laid out in In re Cook, 7 Cal.5th 439 (2019), and did not previously have an opportunity to present evidence related to his status as a juvenile offender. To this, the Court of Appeal concurred, reversed the trial court’s order, and remanded the matter for further proceedings. View "California v. Benzler" on Justia Law

Briones was a leader of a violent gang that “terrorized the Salt River Reservation community.” Briones participated in multiple violent crimes, including a 1994 murder that was committed when Briones was 17 years, 11 months, and eight days old.The Ninth Circuit affirmed his life sentence in 1998. Following the Supreme Court’s decisions in "Miller," (2012), that the Eighth Amendment forbids a sentencing scheme that mandates life without the possibility of parole (LWOP) sentences for juvenile offenders, and Montgomery, (2016), that Miller’s rule applied retroactively on collateral review, Briones was resentenced to LWOP in 2016. A Ninth Circuit panel affirmed in 2018. The en banc court subsequently vacated the sentence. The Supreme Court remanded in light of Jones v. Mississippi, (2021), holding that in cases involving LWOP defendants, a discretionary system—where a sentencer can consider the defendant’s youth and has discretion to impose a lesser sentence—is constitutionally sufficient--and that permanent incorrigibility is not an eligibility criterion for the imposition of juvenile LWOP sentences; a sentencer need not provide an on-the-record explanation with an implicit finding of permanent incorrigibility.The Ninth Circuit again affirmed the LWOP sentence. The district court did consider Briones’s post-incarceration rehabilitation and there is no independent requirement that a court imposing juvenile LWOP “meaningfully engage” in a permanent-incorrigibility analysis. Briones waived his as-applied challenge to the substantive proportionality of his sentence. The court rejected “Briones’s wholly speculative arguments advocating for categorical bans on juvenile LWOP.” View "United States v. Briones" on Justia Law

Antioch police officers, responding to a call about a prowler, tried to stop a Pontiac sedan that the caller had identified. Officers in different vehicles pursued the Pontiac. At one point, an officer started to exit his vehicle with his firearm drawn. The Pontiac accelerated toward the officers, striking the driver’s door on the first vehicle so that it slammed on the officer’s ankle. The Pontiac hit the bumper on the second vehicle, causing no noticeable damage. The Pontiac sideswiped and scratched the third vehicle. After an extended chase with pursuit by a helicopter, officers apprehended the occupants of the Pontiac, including the driver (the minor).The court sustained a petition under Welfare and Institutions Code 602(a) for evasion of a peace officer while driving in willful disregard of others, deadly weapon assault on a peace officer, and force-likely assault. The court of appeal reversed in part. The punishment on the reckless evasion of police count must be stayed because it is based on the same indivisible course of conduct with the same intent and objective as the assault counts. The juvenile court must designate counts 1 and 3 as felonies or misdemeanors. The court rejected an argument that the finding on force-likely assault must be vacated because it is a lesser included offense of deadly weapon assault on a peace officer and is based on the same conduct. View "In re L.J." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

The Court of Appeal reversed a postjudgment order denying defendant's petition for resentencing under Penal Code section 1170.95 as to his conviction of first degree murder under a theory of felony murder based on his participation in an attempted carjacking. The court agreed with defendant that substantial evidence does not support the trial court's conclusion that he was a major participant in the underlying felony and acted with reckless indifference to human life.In this case, defendant did not provide the murder weapon, instruct his confederate to shoot, or know of his confederate's propensity toward violence, and the shooting occurred quickly without defendant having a meaningful opportunity to intervene. Although defendant was aware his confederate had a gun and intended to use it in the carjacking, as a 15-year-old he may well have lacked the experience and maturity to appreciate the risk that the attempted carjacking would escalate into a shooting and death, and he was more susceptible to pressure from his fellow gang members to participate in the carjacking. The court also agreed with defendant that Proposition 57 and Senate Bill 1391 apply to defendant's resentencing under section 1170.95 and directed the trial court to transfer the matter to the juvenile court. View "People v. Ramirez" on Justia Law

In 2020, a juvenile wardship petition was filed charging D.C. with committing a murder in 2016, when he was 16 years old. The probation officer’s report reviewed the statutory factors relevant to a transfer out of juvenile court and recommended transfer, finding D.C. exhibited criminal sophistication, that D.C. was 20 years old and it was difficult to predict how he may mature in the next five years, that D.C.’s delinquent history included a 2014 wardship referral for battery involving a physical fight at school. D.C. also had “a pattern of delinquency” at school, D.C. admitted to abusing alcohol, marijuana, and Xanax, and that the circumstances and gravity of the alleged offenses were serious compared to other homicides.The juvenile court granted a motion to transfer him from juvenile court to a court of criminal jurisdiction (Welf. & Inst. Code 707(a)(1)). The court of appeal denied a petition challenging the transfer. The juvenile court did not err in considering D.C.’s 2017 burglary or the behavior documented in his school records. The finding that he was not likely to be rehabilitated before the expiration of juvenile court jurisdiction is supported by substantial evidence. The court also rejected challenges to expert testimony and evidentiary rulings. View "D.C. v. Superior Court" on Justia Law

The Supreme Court reversed the judgment of the circuit court committing seventeen-year-old D.S. to the custody of the Department of Corrections (DOC) pursuant to S.D. Codified Laws 26-8C-7 after adjudicating him of first-degree rape, holding that the court committed reversible error because its findings and conclusions were insufficient to permit meaningful review.In announcing its disposition, the circuit court did not address whether the recommendations before it for community supervision and outpatient treatment were viable alternatives to DOC custody or whether commitment to the DOC was the least restrictive alternative in D.S.'s best interest. The day after the deposition hearing, the court entered written findings of fact and conclusions of law stating simply that there were no other viable alternatives and that commitment to the DOC was the least restrictive alternative. The Supreme Court reversed, holding that remand was required for the circuit court to make findings on the viability of a community-based supervision and treatment alternative and to reimpose a disposition consistent with the requirements of section 26-8C-7. View "In re D.S." on Justia Law

The Supreme Court affirmed the order of the circuit court granting the State's motion to transfer this juvenile case to the criminal jurisdiction of the circuit court pursuant to W. Va. Code 49-4-710, holding that there was no error.Petitioner, the juvenile in this case, was seventeen years and seven months old when he was charged with child abuse resulting in serious bodily injury and child neglect resulting in serious bodily injury. The state police filed a juvenile petition alleging that Petitioner was a delinquent child. The State filed a motion to transfer Petitioner's juvenile proceedings to the circuit court's criminal jurisdiction. The circuit court granted the State's motion. The Supreme Court affirmed, holding that the circuit court did not err in transferring the case to the criminal jurisdiction of the circuit court. View "In re C.B." on Justia Law

M.S. and J.G. argued during a high school class. J.G. hit M.S. with a small book. J.G. was suspended for two days. About a month later, J.G. accused M.S. of taking her backpack. M.S. pulled a rectangular device with protruding antennas out of her bag, turned it on, and said “[t]ry that again, I’m going to tase you.” A spark erupted from the device. J.G. thought the device was a taser and retreated. The principal learned of the incident.The school resource officer, Reed, took custody of the device, identifying it as an “over-the-counter” stun gun. He did not know the weapon’s voltage and testified that the “capability” of a stun gun depended on its voltage. He initially opined that M.S.’s stun gun probably could not immobilize a person but later noted that it could immobilize a person of smaller stature, and, depending on their size, age, and medical condition, could “in some cases even cause death.” The juvenile court found that M.S. brought a stun gun into school, sustained the Penal Code 626.10(a) allegation, reduced the offense to a misdemeanor, adjudicated M.S. a ward of the court, and placed her in her mother’s custody with probation conditions. The court of appeal reversed. There was insufficient evidence to support a finding that the weapon was capable of temporarily immobilizing a person and, therefore, that it qualified as a stun gun under sections 626.10(a) and 244.5(a). View "In re M.S." on Justia Law