Justia Juvenile Law Opinion Summaries

The Supreme Judicial Court affirmed the order of the juvenile court judge denying a juvenile's motion for relief from sex offender registration, holding that the record below was inadequate for the Court to decide the constitutional issue presented by the juvenile in this case.After the juvenile court judge denied the juvenile's motion to be relieved from his obligation to register as a sex offender the juvenile filed a petition seeking relief under Mass. Gen. Laws ch. 211, 3, arguing that requiring juveniles to register violates due process and constitutes cruel and unusual punishment based on advances in the understanding of the adolescent brain. The Supreme Judicial Court denied relief, holding (1) based on the record, the judge's determination that the juvenile should not be relieved of the obligation to register as a sex offender did not lie outside the bounds of reasonable alternatives; and (2) because of the absence of expert testimony and the failure to properly introduce the scientific studies cited in the judge's written findings, the Court did not have the necessary record to reach the constitutional issue. View "Ernest E. v. Commonwealth" on Justia Law

Kevin was charged in juvenile court with a murder he allegedly committed at age 17. A contested hearing under Welfare and Institutions Code section 707(a)(1) lasted several days. The juvenile court was presented with evidence demonstrating both the heinousness of the crime and that Kevin was raised by a loving family, had no prior criminal history, suffered little past trauma, and had no significant psychological or behavioral issues. Kevin’s juvenile hall behavior was exemplary. The juvenile court concluded that Kevin was unfit for the juvenile system and transferred him to criminal court, acknowledging “a certain tragedy” in its ruling. The court of appeal remanded for reconsideration. The court’s findings regarding section 707’s gravity and criminal-sophistication criteria are supported by substantial evidence but the court improperly evaluated section 707’s rehabilitation criterion, which it deemed its “most significant” consideration. A court cannot determine a juvenile’s rehabilitative needs based solely on the gravity of the offense, and the standard seven-year parole consideration period that applies to juveniles committed to the Department of Juvenile Justice for murder does not establish a presumptive rehabilitation period. View "Kevin P. v. Superior Court" on Justia Law

John Doe was a minor at the time the State alleged he committed two counts of lewd and lascivious conduct against a minor under the age of sixteen. Doe maintained his innocence, but argued that even if he did commit the acts alleged, the petition was time-barred under the four-year, catch-all limitation for civil actions found in Idaho Code section 5-224. The magistrate court (“juvenile court”) denied Doe's motion to dismiss the petition as untimely, and thereafter granted the State’s motion to waive Doe into adult proceedings. On intermediate appeal, the district court affirmed the decision of the juvenile court. The issue presented for the Idaho Supreme Court's review was whether proceedings under the Juvenile Corrections Act ("JCA") were "civil actions" subject to a civil statute of limitations. The Court concluded they were not, and affirmed the juvenile court, finding at JCA petition was not subject to the limitation in Idaho Code 5-224. View "Idaho v. Doe" on Justia Law

In 2009, Lopez was convicted in criminal court of murder and related charges based on his actions at age 17. In 2019, the court recalled his sentence and resentenced him under Penal Code section 1170(d)(1) to remove a gang-benefit enhancement in light of an intervening California Supreme Court decision. Before the resentencing, Lopez moved to have a juvenile court hold a transfer hearing based on 2016’s Proposition 57, which eliminated prosecutors’ ability to directly file charges against minors in criminal court; a juvenile court must first conduct a “transfer hearing” to determine whether a matter should remain in juvenile court or be transferred to adult court. The trial court denied the motion concluding that Proposition 57 did not apply despite the resentencing, because Lopez’s original sentence became final before Proposition 57 took effect.The court of appeal conditionally reversed and remanded for a juvenile court to conduct a transfer hearing. Because section 1170(d)(1) resentencing replaces the original sentence, the only sentence that matters is the new sentence, which is not final because a resentenced defendant can still obtain review from the California Supreme Court or the U.S. Supreme Court. The mere existence of the resentence makes the original sentence irrelevant. Lopez is entitled to a retroactive transfer hearing. View "People v. Lopez" on Justia Law

Consistent with People v. Elizalde (2015) 61 Cal.4th 523, the Court of Appeal held that the routine booking question exception to Miranda v. Arizona (1966) 384 U.S. 436, categorically applies to all of the core booking questions enumerated in Pennsylvania v. Muniz (1990) 496 U.S. 582, 601-602, and authorizes the admission of the defendant's answers to those specific questions into evidence without the need to assess those questions' incriminatory nature on a case-by-case basis.The Court of Appeal affirmed the juvenile adjudication in this case, holding that the trial court did not err in admitting the officer's testimony regarding the minor's answers to the booking questions about his age and date of birth, both of which fall squarely within Muniz's categories of basic biographical data. Therefore, there was sufficient evidence to support the juvenile court's adjudication. View "The People v. J.W." on Justia Law

In 2014, a jury convicted Lizarraga of second-degree murder and found that he personally used a firearm in connection with the shooting of a rival gang member. Lizarraga was 17 years old when he committed the crime. He was sentenced to 40 years to life in state prison. After his first appeal, Lizarraga filed a “Franklin” habeas corpus petition, requesting an opportunity to make a record relevant to his eventual youth offender parole hearing. The court granted the petition and set a hearing date. Lizarraga next moved for a transfer hearing in juvenile court under the Public Safety and Rehabilitation Act of 2016 (Proposition 57). The trial court denied the motion.The court of appeal affirmed, concluding that Lizarraga’s case was final when he requested the transfer hearing. Proposition 57 does not apply to final judgments. The Franklin hearing aside, Lizarraga’s case was final in June 2016, upon expiration of the time to seek U.S. Supreme Court review. The court rejected an argument that whenever a Franklin hearing is scheduled, finality is undone and all intervening changes in the law are in play. Lizarraga’s equal protection challenge is without merit. No “equal protection violation aris[es] from the timing of the effective date of a statute lessening the punishment for a particular offense.” View "People v. Lizarraga" on Justia Law

In 2002, Lusby was convicted of first-degree murder, aggravated criminal sexual assault, and home invasion and sentenced to 130 years’ imprisonment. Though he was 23 years old at the time of the trial, he was only 16 years old at the time of the offenses. After an unsuccessful direct appeal and post-conviction proceedings, he sought leave to file a successive post-conviction petition, asserting that his sentencing hearing was constitutionally inadequate under the Supreme Court’s 2012 decision, Miller v. Alabama. The Will County Circuit Court denied that motion. The appellate court reversed.The Illinois Supreme Court reinstated the trial court’s decision, denying relief. Lusby failed to show cause and prejudice such that the trial court should have granted leave to file a successive post-conviction petition. Lusby had every opportunity to present mitigating evidence but chose not to offer any. The trial court considered his youth and its attendant characteristics before concluding that his future should be spent in prison. The de facto discretionary life sentence passes constitutional muster under Miller; Lusby has not shown prejudice under 725 ILCS 5/122-1(a)(1). Miller does not require a court to use “magic words” before sentencing a juvenile defendant to life imprisonment but only requires consideration of “youth-related factors.” View "People v. Lusby" on Justia Law

The Court of Appeal affirmed defendant's sentence of life without the possibility of parole plus one year for robbery and felony murder with a special circumstance finding under Penal Code section 190.2, subdivision (a)(17), which mandates a sentence of death or life in prison without the possibility of parole. Defendant was 18 years old at the time that he stabbed and killed a 15 year old boy.The court held that the felony murder special circumstance statute is not unconstitutionally vague as applied to defendant where the trial court instructed the jury on the independent felonious purpose rule, and defendant had notice of the conduct proscribed by section 190.2 and does not claim discriminatory prosecution. The court explained that the fact that the prosecutor had discretion to charge defendant under two statutes with different penalties does not render the statutory scheme unconstitutional. The court also held that defendant's sentence is not cruel and unusual under the Eighth Amendment; defendant forfeited his right to challenge the restitution fine and assessments; and the trial court's sentencing minute order and the abstract of judgment must be corrected because the trial court erred in imposing a parole revocation fine. View "People v. Montelongo" on Justia Law

The Supreme Court held that consecutive sentences imposed for separate crimes, when the cumulative sentences exceed a juvenile's life expectancy, do not violate the Eighth Amendment, as interpreted in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016).Defendants in these cases argued that their sentences violated the Eighth Amendment. At issue was whether Graham, Miller, and Montgomery prohibit aggregated consecutive sentences for separate crimes that exceed a juvenile's life expectancy. The Supreme Court held that Graham, Miller, and Montgomery do not prohibit such de facto life sentences, and therefore, Graham and its progeny do not constitute a significant chance in the law under Ariz. R. Crim. P. 32.1(g). View "State v. Soto-Fong" on Justia Law

Juvenile A.P. appealed an adjudication of delinquency based on “open and gross lewdness and lascivious behavior” under 13 V.S.A. section 2601. Juvenile argued: (1) the evidence did not support a finding that his conduct was open or gross; (2) section 2601 was ambiguous and therefore unenforceable against him; and (3) section 2601 was unconstitutionally vague. The incident giving rise to the adjudication at issue here dated back to 2018, when Juvenile approached the complainant in the hallway of school. Complainant testified: “[A]ll of a sudden, he asked if he could touch my breasts, and then he just reached out, and his hand was on me.” No one else was present, although school was in session. When juvenile touched complainant’s breast with his hand, she turned around and ran. She was furious and upset. Juvenile testified that he reached out his hand toward complainant’s chest but never touched it. He testified that he regretted disregarding complainant’s feelings and felt his actions were “disgusting.” The family court found complainant to be credible. It concluded that juvenile had touched her breast and in doing so had committed a delinquent act. The Vermont Supreme Court concluded the court’s findings were supported by the record. The Court further concluded the statute unambiguously proscribes the type of conduct at issue here, and accordingly affirmed the judgment. View "In re A.P., Juvenile" on Justia Law