Justia Juvenile Law Opinion Summaries

Michael Damion Jude Medrano was convicted by jury on one count of first-degree murder, two counts of second degree robbery, and one count of assault with force likely to produce great bodily harm. Medrano was 19 years old when he committed the offenses. He was sentenced to 25 years to life, plus seven. Medrano was sentenced in December 2017, one and one-half years after the California Supreme Court decided California v. Franklin, 63 Cal.4th 261 (2016), which held that when a juvenile offender receives an indeterminate life sentence, the offender must be “given adequate opportunity at sentencing to make a record of mitigating evidence tied to his youth.” The Court remanded the case to the trial court to determine whether the juvenile offender had been given an adequate opportunity to make such a record. Medrano asked the Court of Appeal to give him the same relief that was granted in Franklin. But because Medrano was sentenced one and one-half years after Franklin, and because nothing in the record indicated Medrano lacked an adequate opportunity at sentencing to make a record of mitigating youth-related evidence, the Court found no basis to order the same relief that the Supreme Court granted in Franklin. It noted, however, that the Supreme Court recently held that a juvenile offender whose conviction and sentence were final could file a motion under Penal Code section 1203.01 for the purpose of making a record of mitigating youth-related evidence. View "California v. Medrano" on Justia Law

In a moot case of substantial and continuing public interest, a juvenile offender challenges whether her need for treatment was an appropriate basis for imposing a manifest justice disposition. B.O.J. pled guilty to two counts of third degree theft for shoplifting from a grocery store. These offenses subjected her to a "local sanctions" standard sentencing range. In exchange for a plea, the prosecution promised to recommend 6 months of community supervision, 8 hours of community service, credit for time served, release at her sentencing disposition, and no contact with the victims. One month later, the State contended B.O.J. violated the conditions of her release by running away from placement. The State thereafter recommended a manifest justice disposition with confinement in a Juvenile Rehabilitation Administration facility. The trial court stated its findings that both B.O.J.'s need for treatment and the standard sentencing range as too lenient supported the manifest injustice disposition. The Washington Supreme Court determined the trial court's findings were not an appropriate basis for imposing a manifest injustice disposition. The Court reversed the Court of Appeals' holding that B.O.J.'s need for treatment supported the trial court's finding that a standard range disposition would effectuate a manifest injustice. View "Washington v. B.O.J." on Justia Law

This case centered on the validity of a a changed law that raised the minimum age at which a juvenile could be tried in criminal court. The new law amended a provision of the “Public Safety and Rehabilitation Act” (Proposition 57), which the voters approved in 2016 with the express goals of reducing prison spending, emphasizing rehabilitation for youth offenders, and limiting prosecutorial authority over the decision to try a minor as an adult. To advance these goals, Proposition 57 eliminated prosecutors’ ability to directly file charges against minors ages 14 to 17 in criminal court, requiring them instead to seek the juvenile court’s permission by way of a transfer hearing. In 2018, the Legislature enacted the law at issue here, Senate Bill Number 1391 (2017-2018 Reg. Sess., "SB 1391"), which eliminated prosecutors’ ability to seek transfer hearings for 14 and 15 year olds, effectively raising the minimum age a child can be tried as an adult from 14 to 16. The change affected B.M.’s prosecution for murder. SB 1391 became effective after the Riverside County District Attorney had filed a wardship petition against the then 15-year-old, and had moved to transfer her to criminal court. While the transfer motion was pending, the juvenile court (respondent Riverside County Superior Court) ruled the new law was invalid because it did not further what it identified as Proposition 57’s goal of giving judges the authority to transfer 14 to 17 year olds to criminal court. B.M. sought mandamus relief, arguing the trial court misinterpreted Proposition 57's purpose in declaring SB 1391 invalid. The Court of Appeal agreed, finding SB 1391 furthered each of Proposition 57’s express purposes, including the one concerned with limiting prosecutorial discretion. The Court therefore granted B.M.’s petition for a writ of mandate and directed the juvenile court to vacate its order declaring SB 1391 invalid. View "B.M. v. Superior Court" on Justia Law

Senate Bill No. 1391 is unconstitutional insofar as it precludes the possibility of adult prosecution of an alleged 15-year-old murderer. In this case, the district attorney sought to try petitioner as an adult after he killed two people when he was fifteen years old. Proposition 57, an initiative passed by the voters allows the district attorney, with the approval of the superior court, to try him as an adult. However, SB 1391 prohibited asking the superior court for such permission.The Court of Appeal denied the petition for extraordinary relief, holding that the superior court correctly ruled that the initiative authorizes the possibility of treating a 15-year-old alleged murderer as an adult and that S.B. 1391 precludes this possibility. The court explained that this attempt to "overrule" Proposition 57 violates the well settled rule that the Legislature may not enact a law that thwarts the initiative process without the consent of the people. View "O.G. v. Superior Court of Ventura County" on Justia Law

At the time of the crimes, petitioner D’Arsey Bolton was 16. He accosted two young girls, aged 10 and 12, while they were at school, forcing each at knifepoint into a bathroom, where he threatened them and raped them. Petitioner was convicted in Contra Costa County of five counts of rape, two counts of unlawful penetration with a foreign object, two counts of forcible lewd and lascivious conduct on a child, two counts of false imprisonment, one count of attempted rape, and one count of assault with a deadly weapon, along with multiple enhancements for being armed with and using a knife and pellet pistol. He was sentenced to 92 years in state prison, which was modified to 91 years on appeal. Over a decade later (when petitioner was 30), a correctional officer discovered a metal object wrapped in cloth in petitioner’s cell. Petitioner claimed he needed the weapon for protection while in jail. He would later be conviction of possessing a sharp instrument in prison. He admitted 11 strike allegations and was sentenced to 25 years to life under the three strikes law. In this habeas proceeding, petitioner claimed his sentence violated the cruel and unusual punishment prohibition of the Eighth Amendment and asked the Court of Appeal to order Superior Court to resentence him on all of his convictions consistent with the possibility of release in his lifetime, or to find he was not ineligible for youth offender parole. The Court of Appeal found resentencing on the juvenile offenses was necessary, but petitioner’s adult sentence did not violate the Eighth Amendment. The Court therefore vacated the 91-year term for the crimes committed as a juvenile, and remanded for resentencing. View "In re Bolton" on Justia Law

During his high school senior year, Frank had an encounter with the school’s new resource officer, Redwood City Officer Stahler. Frank’s father filed a complaint alleging Stahler had physically handled Frank in an unlawful manner. An investigation followed but Stahler continued at the school. Months later, Frank and three others left a class without permission. Frank was found in the library. An aide directed him to the administrative vice principal’ office, where Stahler was located. Frank called his father on his cell phone and told the aide he wanted to go to the principal’s office instead but generally cooperated with the aide. Stahler arrived and reprimanded Frank about using the phone in violation of school rules. There was physical contact; the two dispute the nature of the confrontation. Eventually, Stahler grabbed his wrist, forced Frank to the ground, handcuffed him and arrested him. The juvenile court sustained charges of misdemeanor battery and resisting a peace officer. The court of appeal reversed. Stahler did not indicate that Frank acted willfully or unlawfully to touch him. There is no substantial evidence that Frank’s touching Stahler, even if willful, was “harmful or offensive,” another required element of battery. There is no indication Stahler was enforcing any disciplinary rules during the encounter. Given Stahler’s failure to give Frank any clear or direct orders, there was insufficient evidence that Frank willfully resisted Stahler. View "People v. Francis A." on Justia Law

After a spree of San Pablo parking lot robberies and purse snatchings, officers found the victims' property in a vehicle occupied by 17-year-old Alonzo and two others. Alonzo admitted to grand theft of a person, taking property valued at more than $950, The court dismissed the other charges, ordered that Alonzo be placed on GPS monitoring and released to his mother's custody, and transferred the case to Contra Costa County. That court ordered that Alonzo was to have no contact with his “co-responsibles.” A supplemental petition alleged that Alonzo committed three additional felonies during the crime spree. Alonzo expressed remorse, blamed peer pressure, denied using alcohol and reported that he had been smoking marijuana once a day for chronic migraines. This was Alonzo’s first referral. The disposition order placed him on probation. Alonzo challenged a probation condition: In light of ... concern about your association in Oakland, … you must submit your cell phone or any other electronic device under your control to a search of any medium of communication reasonably likely to reveal whether you’re complying with the terms of your probation with or without a search warrant at any time ... text messages, voicemail messages, photographs, e-mail accounts, and other social media accounts and applications. You shall provide access codes ... upon request .” The court of appeal upheld the decision to impose an electronic search condition but concluded the condition sweeps too broadly and remanded. View "In re Alonzo M." on Justia Law

S.L. was 15 years old at the time of the murder. The prosecution charged S.L. with murder and attempted murder and filed a juvenile wardship petition, alleging that S.L. personally and intentionally discharged a firearm in the commission of the offense and that S.L. was a principal in the offense. Proposition 57 requires prosecutors charging a minor aged 14 or older at the time of the offense to seek juvenile court approval to transfer the minor to adult criminal court. In 2018, SB 1391 prohibited the transfer of 14- and 15-year-old minors to criminal court in most cases. After the court refused to hold a transfer hearing concerning S.L., the prosecution challenged SB 1391 as impermissibly eliminating a court’s ability to transfer jurisdiction over a 15-year-old charged with murder to adult criminal court. The court ruled that SB 1391 is constitutional and did impact S.L.’s case. The court of appeal denied the District Attorney’s petition for mandamus relief. SB 1391 is constitutional; it is consistent with and furthers the intent of Proposition 57. “[T]he intent of the electorate in approving Proposition 57 was to broaden the number of minors who could potentially stay within the juvenile justice system, with its primary emphasis on rehabilitation rather than punishment.” View "People v. Superior Court" on Justia Law

A.S. was adjudicated a juvenile delinquent under the Federal Juvenile Delinquency Act (“FJDA”) after the district court concluded that, when he was seventeen years old, he knowingly engaged in a sexual act with a victim, K.P., while she was incapable of appraising the nature of the conduct. The court ordered A.S. to be committed to eighteen months’ custodial detention to be followed by twenty-four months’ juvenile-delinquent supervision. On appeal, A.S. raised three challenges: (1) the district court erred in limiting cross-examination and excluding extrinsic evidence concerning a prior allegation of sexual assault that K.P. made; (2) the evidence was insufficient to demonstrate that he knew that K.P. was incapable of appraising the nature of the sexual conduct, which he says was an element of the offense; and (3) the district court erred in imposing a dispositional sentence on him of custodial detention. The Tenth Circuit concluded: (1) the district court’s actions accorded with the Federal Rules of Evidence and did not violate A.S.’s constitutional rights; (2) there was ample evidence for a reasonable factfinder to determine A.S. engaged in sexual conduct with K.P. while he knew she was asleep and drunk; and (3) the sentence did not constitute an abuse of the district court's broad sentencing discretion. Thus, the Tenth Circuit affirmed judgment. View "United States v. A.S." on Justia Law

A.W. committed five counts of felony vandalism. The court declared minor a ward of the state and ordered him to serve 37 days in juvenile hall. The sole question on appeal was whether the evidence supported a finding that, for each count, “the amount of defacement, damage, or destruction [was] four hundred dollars ($400) or more,” as required to elevate the crime from a misdemeanor to a felony. The Court of Appeal determined the only competent testimony on that issue came from an employee of the City of Palmdale who helped prepare an analysis of the average cost to clean up an instance of graffiti. The Court determined: (1) use of an average, by itself, was not enough to prove beyond a reasonable doubt that the amount of damage inflicted by minor was equal to the average cleanup cost, rather than some other number; (2) the calculation included the cost of law enforcement, which, though proper in certain restitution settings, was not a proper consideration in assessing the damage minor inflicted under the applicable statute; and (3) Palmdale’s methodology for calculating the average cost is flawed. The Court reversed adjudication in part with direction to reduce the felony counts to misdemeanors. View "In re A.W." on Justia Law