Justia Juvenile Law Opinion Summaries

Two boys from Grand Junction, Colorado, were sexually abused by Michael Tracy McFadden over several years. McFadden, who was distantly related to one boy (J.W.) and a close family friend to the other (K.W.), provided necessities and luxuries to the boys, ingratiating himself with their families. The boys frequently stayed at McFadden’s house, where he assaulted them during the night. McFadden also took the boys on interstate trucking trips, during which he continued the abuse.McFadden was initially convicted in Colorado state court on nineteen counts of child-sex abuse, but the Colorado Court of Appeals dismissed the charges due to a violation of his speedy-trial rights. Subsequently, a federal grand jury charged McFadden with five counts related to his sexual abuse of J.W. and K.W. across state lines. The United States District Court for the District of Colorado admitted a video recording of K.W.’s 2013 forensic interview under Rule 807, despite McFadden’s objections. The jury convicted McFadden on all counts, and he was sentenced to concurrent life sentences.The United States Court of Appeals for the Tenth Circuit reviewed McFadden’s appeal, which argued that evidentiary errors and a mistake in his Guidelines calculation warranted a new trial and resentencing. The court found that the district court erred in admitting the 2013 forensic-interview video under Rule 807 but deemed the error harmless. The court also upheld the district court’s exclusion of an audio recording of K.W.’s 2018 interview and rejected McFadden’s claims of improper vouching by witnesses. Finally, the court affirmed the application of a two-level undue-influence enhancement to McFadden’s sentence under U.S.S.G. § 2G1.3(b)(2)(B). The Tenth Circuit affirmed McFadden’s conviction and sentence. View "U.S. v. McFadden" on Justia Law

In 2017, a minor admitted to two counts of assault with intent to commit rape and was initially placed in a Level B program. Due to multiple probation violations, the juvenile court later committed him to the Division of Juvenile Justice (DJJ) in 2019. After being discharged from DJJ in April 2023, the juvenile court imposed a probation condition requiring the minor to register as a sex offender under Penal Code section 290.008. The minor appealed, arguing that this requirement violated his equal protection rights because it treated him differently from minors who committed similar offenses after the juvenile justice realignment, which closed DJJ and transferred responsibilities to county facilities.The Superior Court of Sacramento County upheld the probation condition, rejecting the minor's equal protection argument. The court found that the sex offender registration requirement did not involve a loss of liberty and thus did not implicate a fundamental right, applying the rational basis standard of review. The court reasoned that the Legislature could have determined that minors in county facilities have a lower risk of recidivism due to more effective treatment, justifying the differential treatment.The California Court of Appeal, Third Appellate District, reviewed the case de novo and affirmed the lower court's decision. The court held that the rational basis standard applied because the sex offender registration requirement did not involve a fundamental right or suspect classification. The court found that a rational basis existed for the differential treatment, as the Legislature could have reasonably concluded that minors already in DJJ custody posed a higher risk of recidivism and required continued registration to protect public safety. Thus, the court found no equal protection violation and affirmed the dispositional order. View "People v. I.B." on Justia Law

Andrew McCurdy entered a plea agreement in February 2022, pleading guilty to felony criminal mischief and agreeing to pay restitution. The District Court ordered a presentence investigation (PSI) report, which included McCurdy’s juvenile records without a Youth Court order. McCurdy filed motions to strike the juvenile records from the PSI and to determine his ability to pay certain fees. The District Court denied the motion to strike, stating the records were provided pursuant to a court order, and imposed a $50 PSI fee and probation supervision costs without inquiring into McCurdy’s ability to pay.The Eleventh Judicial District Court denied McCurdy’s motion to strike his juvenile records, reasoning that the records were provided under a court order and could be considered at sentencing. The court also imposed the PSI fee and probation supervision costs without determining McCurdy’s ability to pay, despite his motion requesting such an inquiry. McCurdy appealed these decisions.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision to include McCurdy’s juvenile records in the PSI, finding that any error in the procedure was harmless as McCurdy did not demonstrate prejudice. However, the Supreme Court reversed the imposition of the $50 PSI fee and probation supervision costs, noting that the District Court failed to inquire into McCurdy’s ability to pay, as required by law. The case was remanded for the District Court to conduct the necessary inquiry into McCurdy’s financial situation before imposing these costs. View "State v. McCurdy" on Justia Law

Tina Sully, a foster parent for the Yankton Sioux Tribe, was charged with multiple counts of abusing her three adopted children. The charges stemmed from an incident where 13-year-old C.S. ran away from home and reported to neighbors and authorities that Sully had physically abused her and withheld food. An investigation revealed similar allegations from two other foster children, D.F.H. and G.S. Sully was indicted on ten counts, including assault with a dangerous weapon and felony child abuse.The first trial in the United States District Court for the District of South Dakota ended in a mistrial due to a hung jury. The court scheduled a second trial to begin eighteen days later. Sully requested a continuance twice, citing her counsel's scheduling conflicts and the unavailability of key defense witnesses, but both motions were denied. The second trial proceeded, and Sully objected to the admission of several out-of-court statements under Federal Rules of Evidence 803(2) and 807, which the court admitted.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Sully's motions for a continuance, as she failed to demonstrate how the denial prejudiced her defense. The court also found that even if the admission of the challenged hearsay statements was erroneous, it was harmless error given the overwhelming evidence against Sully, including testimony from C.S., medical professionals, and other witnesses.The Eighth Circuit affirmed the district court's decisions, upholding Sully's convictions on all counts related to C.S. The court concluded that the denial of the continuance and the admission of hearsay evidence did not warrant a new trial. View "United States v. Sully" on Justia Law

In 1984, Roger Scott Helm, Jr., then 14 years old, murdered his adoptive parents and stepsister. He was arrested and charged with multiple counts, including first-degree murder. Helm pleaded guilty to one count of first-degree murder, two counts of second-degree murder, and one count of armed robbery. The trial court sentenced him to life imprisonment for the first-degree murder with eligibility for parole after 25 years, followed by consecutive sentences totaling an additional 42 years for the other counts.Helm's case was transferred from juvenile to adult court, and he was sentenced after a detailed hearing where the court considered mitigating factors such as his age and drug influence, as well as aggravating factors like his lack of remorse and dangerousness. The Arizona Supreme Court upheld the consecutive sentences on direct appeal.Helm later filed for post-conviction relief, arguing that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Arizona trial court and the Arizona Court of Appeals rejected his claim, stating that Miller does not apply to consecutive sentences for multiple crimes. The Arizona Supreme Court denied review.The United States Court of Appeals for the Ninth Circuit reviewed Helm's habeas corpus petition. The court assumed, for argument's sake, that Helm's sentence was the functional equivalent of life without parole. However, it concluded that Helm's sentence complied with Miller because the trial judge had discretion and considered Helm's youth before imposing the sentence. The Ninth Circuit affirmed the district court's denial of Helm's habeas corpus petition, holding that Helm's sentence did not violate the Eighth Amendment as interpreted in Miller and clarified in Jones v. Mississippi. View "Helm v. Thornell" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

In 2015, J.M., then 17, broke into a 72-year-old woman's home, assaulted her with intent to commit rape, and stole $900. The People filed charges directly in adult criminal court under former section 707. A jury found J.M. guilty of assault with intent to commit rape during a burglary, attempted rape, and first-degree robbery, with an elder abuse enhancement. He was sentenced to 14 years to life.J.M. appealed, arguing that Proposition 57, which eliminated direct charging of juveniles in adult court, should apply retroactively. The California Supreme Court in People v. Superior Court (Lara) agreed, holding that Proposition 57 applies retroactively to nonfinal cases. The Court of Appeal conditionally reversed J.M.'s judgment and remanded for a juvenile transfer hearing. The juvenile court, after a hearing, transferred J.M. to adult court, reinstating his sentence. J.M.'s appeal of this order was dismissed, but he later successfully petitioned for habeas corpus, leading to the reentry of the transfer order and this appeal.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that recent amendments to section 707, which raised the prosecution's burden of proof and required specific findings regarding a minor's amenability to rehabilitation, apply retroactively to J.M.'s case. The court conditionally reversed the transfer order and remanded for a new transfer/amenability hearing under the amended law. If the juvenile court again transfers J.M. to adult court, the criminal court must conduct a new sentencing hearing considering recent ameliorative changes in sentencing laws. View "In re J.M." on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law