Justia Juvenile Law Opinion Summaries

The case involves Santiago Gonzalo Canales, who was convicted for lewd acts and continuous sexual abuse of children. Canales sexually abused his stepdaughter and niece for over a decade, both of whom were under the age of 14 during the abuse. He was charged with four counts, including lewd acts on his niece and continuous sexual abuse of his niece and stepdaughter. The trial lasted eight days, and the jury convicted Canales on all counts, sentencing him to 60 years to life in prison.Canales appealed his convictions, challenging two different jury instructions. He argued that the first instruction did not identify the correct mental states for the offense of continuous sexual abuse. The court upheld the instruction, stating that it was in line with the presumption of mandatory culpability. Canales's second challenge was to another instruction, which the court assumed was given in error, but held that the error was harmless. Canales also forfeited a third challenge. However, on his fourth point, the court agreed with both parties that Canales must be resentenced.The Court of Appeal of the State of California Second Appellate District affirmed Canales's convictions, vacated his sentence, and remanded the case for resentencing without applying the One Strike law. View "People v. Canales" on Justia Law

The case involves Norman Thurber, who was convicted of six counts of production of child pornography. The charges stemmed from videos found on Thurber's cell phone, which depicted him engaging in sexual acts with a minor female. Thurber was sentenced to 20 years' imprisonment on each count, with the sentences running concurrently, and 10 years of supervised release to follow. Thurber appealed, challenging various trial rulings, the sufficiency of the evidence, and the district court's imposition of standard conditions of supervised release in the written judgment that it did not orally pronounce at sentencing.The district court had ruled that Thurber was not entitled to present mistake of age as an affirmative defense, citing Eighth Circuit precedent. The court allowed Thurber to introduce evidence that the minor represented herself to be 18 years old, but only insofar as it was evidence that she was actually 18 years old, as age was an element of the offense. The jury returned a guilty verdict on all counts.The United States Court of Appeals for the Eighth Circuit affirmed Thurber’s convictions, but vacated the portion of the judgment imposing the standard conditions of supervised release and remanded to the district court for resentencing limited to the standard conditions. The court found that the district court did not err in refusing to allow Thurber to introduce additional portions of the text message exchange between him and the minor. The court also held that the district court did not err in denying Thurber the opportunity to present a mistake-of-age defense. View "United States v. Thurber" on Justia Law

Joseph McGrain was sentenced to 264 months in prison for sexually abusing his then-girlfriend’s fourteen-year-old daughter and obstructing the investigation into the abuse. The district court applied a two-offense-level enhancement under section 2G2.1(b)(5) of the Sentencing Guidelines because the victim was in McGrain’s “custody, care, or supervisory control” when he abused her. The court also denied McGrain an offense-level reduction for acceptance of responsibility because he merited an enhancement for obstruction of justice and continued to deny his sexual relationship with the victim and that he convinced her to send him sexually explicit images.McGrain appealed the district court's decisions, arguing that each was reversible error and that his sentence should be vacated. He also requested that his case be assigned to a different judge on remand.The United States Court of Appeals for the Second Circuit affirmed the judgment of the district court. The court rejected McGrain's arguments, stating that the "custody, care, or supervisory control" enhancement was correctly applied given McGrain's relationship with the victim. The court also affirmed the district court's denial of a reduction for acceptance of responsibility, stating that McGrain had not demonstrated acceptance of responsibility for his actions. Finally, the court found no error in the district court's determination that McGrain was dangerous, which factored into his sentencing. View "United States v. McGrain" on Justia Law

The case involves a minor, A.M., who was convicted as an adult for a murder committed when he was 14 years old. A.M. was a member of a local gang and was convicted of first-degree murder for killing a rival gang member, S.S. The jury found that A.M. had used a deadly weapon and committed the crime for the benefit of his gang. He was sentenced to 26 years to life in state prison.Years later, the superior court conditionally reversed the judgment and ordered a transfer hearing pursuant to Proposition 57, which prohibits trying a minor as an adult without a judicial determination of their fitness for juvenile court law. The juvenile court conducted the hearing, granted the district attorney’s motion to transfer A.M.’s case to criminal court, and reinstated the judgment. A.M. contended that his case should not have been transferred because he was 14 years old when he committed his crime.The Court of Appeal of the State of California, Second Appellate District, Division Six, found that A.M.'s case was nonfinal when the superior court conditionally reversed the judgment. Therefore, Proposition 57 and Senate Bill 1391, which bars a juvenile court from transferring a 14- or 15-year-old to adult criminal court, applied. The court also agreed with A.M.'s contention that Assembly Bill 333 required striking the gang-murder special circumstance. The court reversed the order granting the district attorney’s motion to transfer A.M.’s case to criminal court and vacated the true finding on the gang-murder special circumstance. The court remanded the matter to the juvenile court with directions to enter a new order denying the district attorney’s motion and to hold a dispositional hearing treating A.M.’s murder conviction as a juvenile adjudication. View "In re A.M." on Justia Law

The case involves a juvenile, Jose R., who was declared a ward of the court and committed to a secure youth treatment facility (SYTF) for a baseline term of three years with a maximum term of six years. This followed his admission, as part of a plea deal, that he had committed an assault with a semiautomatic firearm. The case arose from a shooting incident in which Jose and an adult man fired multiple gunshots, resulting in a victim's death. Initially, Jose was charged with first-degree murder, but the charge was later amended to assault with a semiautomatic firearm, which Jose admitted to.The Superior Court of Los Angeles County denied Jose's motion to apply his precommitment custody credits to his baseline term, instead applying the 395 days of precommitment custody credits against the maximum term. Jose appealed this decision, arguing that the court erred in applying his precommitment custody credits to his maximum term instead of his baseline term.The Court of Appeal of the State of California Second Appellate District Division Seven affirmed the lower court's decision. The appellate court found that the lower court did not err in applying Jose's precommitment custody credits to the maximum term of confinement. The court based its decision on the clear statutory language in section 875, subdivision (c)(1)(C), which states that precommitment custody credits must be applied against the maximum term of confinement. The court also rejected Jose's argument that the legislative scheme violated his right to equal protection of the laws. The court concluded that the legislative amendments did not violate equal protection principles, even if they resulted in less favorable treatment of precommitment credits. View "In re Jose R." on Justia Law

The case revolves around Audrey Mae Lessner, who was convicted of felony child abuse under Wyo. Stat. Ann. § 6-2-503(b)(i) (2023) after a bench trial. The charges stemmed from an incident where Lessner, while babysitting an 11-year-old child identified as FF, spanked the child eleven times with a belt as punishment for lying. The spanking resulted in significant bruising on the child's thigh. Lessner appealed her conviction, arguing that the district court abused its discretion by denying her motion to continue the trial and that the State failed to present sufficient evidence to prove that she did not engage in reasonable corporal punishment.Prior to the trial in the District Court of Sweetwater County, Lessner had sought to represent herself, a request that the court granted after advising her of the risks. She later filed a motion for an extension of time, claiming that the prosecution was not assisting her in obtaining information for a subpoena. However, she later informed the court that she no longer needed an extension and was ready for trial. On the first day of the bench trial, Lessner filed a motion for an emergency hearing, asserting that she was not ready to proceed because the State was denying some discovery. The court denied her motion and proceeded with the trial.The Supreme Court of Wyoming affirmed the lower court's decision. It found that the district court did not abuse its discretion in denying Lessner's motion to continue the trial. The court also found that the State presented sufficient evidence to demonstrate that the physical injury inflicted on the child was not the result of reasonable corporal punishment. The court noted that Lessner's actions, including her decision to use a belt to avoid injuring her hand and her refusal to stop spanking the child other than to rest her arm, did not represent a method of correction but rather an adult who had lost control of her own responses. View "Lessner v. The State of Wyoming" on Justia Law

James Massey was charged with gross sexual imposition, a class AA felony, and child abuse, a class C felony. The charges stemmed from an incident involving a minor, identified as T.T. During the trial, the State presented testimonies from T.T., law enforcement, medical staff, and a psychologist. Massey, in his defense, testified on his own behalf. The jury found Massey guilty of both charges.The case was first heard in the District Court of Cass County, East Central Judicial District. At the close of the State's case, Massey moved for a judgment of acquittal under N.D.R.Crim.P. 29, which the court denied. The jury found Massey guilty of both charges, and he subsequently appealed the convictions.The case was then reviewed by the Supreme Court of North Dakota. Massey argued that the jury instruction for gross sexual imposition was improper and that the State's closing arguments constituted prosecutorial misconduct. The Supreme Court affirmed the lower court's decision. The court found no error in the use of "willfully" as the required mens rea in the jury instructions. Although the court acknowledged that the State made an improper "golden rule" argument during closing arguments, it concluded that Massey failed to demonstrate how he was prejudiced by these comments. The court affirmed the judgment of conviction. View "State v. Massey" on Justia Law

In 2013, a minor identified as A.M. was tried as an adult and convicted for first-degree murder of a rival gang member, which he committed at the age of 14. He was sentenced to 26 years to life in prison. In 2021, the superior court conditionally reversed the judgment and ordered a transfer hearing under Proposition 57, which prohibits trying a minor as an adult without a judicial determination of their fitness for juvenile court. The juvenile court conducted the hearing, granted the district attorney’s motion to transfer A.M.’s case to criminal court, and reinstated the judgment.A.M. appealed, arguing that his case should not have been transferred because he was 14 years old when he committed his crime. He also contended that Assembly Bill 333, which amended various provisions of Penal section 186.22, required striking the gang-murder special circumstance. The Court of Appeal of the State of California Second Appellate District agreed with both of A.M.’s contentions.The court held that Senate Bill 1391, which amended Proposition 57 to prohibit the transfer of 14- and 15-year-olds to adult criminal court, applied to A.M.'s case. The court reasoned that when the superior court conditionally reversed A.M.'s conviction and sentence, his case became nonfinal, and thus, Senate Bill 1391 applied. The court also held that Assembly Bill 333 applied retroactively to A.M.'s case, requiring the vacating of the jury's gang-murder special circumstance finding. The court reversed the order granting the district attorney’s motion to transfer A.M.’s case to criminal court, vacated the true finding on the gang-murder special circumstance, and struck the requirement for A.M. to register as a gang offender. The case was remanded to the juvenile court for further proceedings. View "In re A.M." on Justia Law

The case revolves around a defendant who was convicted for enticement of a child. The defendant had approached a ten-year-old girl, A.W., while she was walking her dog. He drove into the opposing lane of traffic to pull his truck up beside her, asked her personal questions, and made inappropriate comments. Based on these events and evidence of the defendant’s previous behavior with a five-year-old girl in Louisiana, a jury convicted the defendant of enticement of a child.The defendant appealed his conviction, arguing that the evidence was insufficient to prove the offense of enticement. The court of appeals agreed with the defendant's argument, vacating his conviction on the ground that the evidence was insufficient to prove that the defendant had attempted to invite or persuade A.W. to enter his truck, or that he intended to commit unlawful sexual contact.The Supreme Court of the State of Colorado disagreed with the court of appeals' interpretation of the term "attempt" in the child enticement statute. The Supreme Court held that the term "attempt" in the statute should be interpreted according to its plain meaning, not as referring to the inchoate crime of "attempt" defined in another statute. The Supreme Court found that the defendant's words and actions, taken together and viewed in the light most favorable to the prosecution, constituted sufficient evidence for a reasonable person to conclude that the defendant attempted to invite or persuade the victim to enter his vehicle with the intent to commit unlawful sexual contact upon her. Therefore, the Supreme Court reversed the court of appeals’ decision vacating the defendant’s conviction and remanded the case to the court of appeals to address his remaining appellate arguments. View "People v. Johnson" on Justia Law

The case involves a juvenile, Jeovani H., who was placed on probation and ordered to pay restitution as a term and condition of his probation. Jeovani was charged with an act that would constitute the felony of first-degree assault, which was later amended to a misdemeanor of attempted third-degree assault. The incident involved Jeovani shoving another youth, causing the youth to fall and fracture his arm. As part of a plea agreement, Jeovani admitted to the amended petition and agreed that the amount of restitution owed to his victim for medical expenses was $2,553.05. However, he disputed his ability to pay that amount.The Hall County Court, sitting as a juvenile court, accepted Jeovani’s admission to the amended petition and ordered a predisposition investigation. At the disposition and restitution hearing, Jeovani’s mother testified about the family's financial situation and work schedules, arguing that Jeovani did not have the ability to pay the restitution amount. The State called Jeovani and a juvenile probation officer as witnesses, who testified about Jeovani's ability to work and earn money to pay the restitution.The Nebraska Supreme Court affirmed the juvenile court's decision. The court found that Jeovani had the ability to pay the restitution within the 12-month period of his probationary term. The court also rejected Jeovani’s claim that he was not allowed an opportunity to present or cross-examine witnesses on the issue of restitution. The court concluded that the restitution order was consistent with Jeovani’s reformation and rehabilitation and was supported by the record. View "In re Interest of Jeovani H." on Justia Law