Justia Juvenile Law Opinion Summaries

The State of New Hampshire filed a petition for original jurisdiction seeking review of a circuit court order denying a request by the Office of the Attorney General (AGO) to release records underlying its investigation into an incident involving minors. According to the AGO, in 2017, there was an incident involving several minors in Claremont, New Hampshire. The AGO, the United States Attorney’s Office, the Federal Bureau of Investigation, and the Claremont Police Department jointly investigated the incident. Subsequently, the Sullivan County Attorney filed delinquency petitions in the circuit court against one of the juveniles. The AGO asserted that the evidence obtained during the investigation was not confidential under RSA 169-B:35 but, even if it were, “significant policy considerations” allowed disclosure as long as the juvenile’s identity was protected. Following a hearing, the trial court rejected the AGO’s argument that RSA chapter 169-B did not apply to the AGO’s investigatory records. The court stated that “RSA 169-B:35 provides that all case records relative to delinquencies are confidential. Publication of information concerning a juvenile case is strictly prohibited with few legislatively enacted exceptions. None of those exceptions apply in this case.” The New Hampshire Supreme Court affirmed the circuit court’s ruling that the records were confidential under RSA 169-B:35 (Supp. 2018). View "Petition of the State of New Hampshire" on Justia Law

For the reasons stated in People v. Superior Court (T.D.), the Court of Appeal rejected the district attorney's claim that Senate Bill No. 1391 unconstitutionally amended Proposition 57. The court also addressed issues not before the court in T.D., and held that Senate Bill No. 1391 is not an unconstitutional amendment of Proposition 21, the Gang Violence and Juvenile Crime Prevention Act of 1998 (Proposition 21); is not unconstitutionally vague; and applies retroactively. In this case, the court held that the murder charge against real party in interest I.R. allegedly committed when he was age 15 cannot be transferred to criminal court based on a separate felony offense he allegedly committed when he was age 17. Therefore, the court denied the petition for writ of prohibition and/or mandate. View "People v. Superior Court (I.R.)" on Justia Law

Senate Bill No. 1391 does not unconstitutionally amend Proposition 57. Proposition 57, the Public Safety and Rehabilitation Act of 2016, eliminated a prosecutor's ability to directly file charges in criminal (adult) court against minors who were 14 years of age or older at the time of their alleged offenses, and instead required prosecutors to obtain juvenile court approval to do so. SB 1391 prohibits the transfer of 14- and 15-year-old offenders to criminal court in virtually all circumstances.The Court of Appeal held that voters intended Proposition 57 to extend as broadly as possible; the amendatory language of section 5 of the Act was ambiguous; and, when the court construed the language and the Act as a whole consistently with the voters' intent, SB 1391 was constitutional. Accordingly, the court discharged the order to show cause previously issued and denied the petition for writ of mandate. View "People v. Superior Court (T.D.)" on Justia Law

A.L. was in a fight with her sister violent enough for police to be called. An officer grabbed A.L.’s arm, stating “I saw you kick her when she was down.” She pulled away. Another officer took her other arm. She dropped to the pavement, kicking and scratching the officer before biting him. He punched A.L. and put her in handcuffs. The District Attorney filed a juvenile wardship petition under Penal Code sections 243(b) (battery on a peace officer); 69 (resisting a peace officer by force); and 148(a)(1) (resisting a peace officer). Resisting an officer and forcefully resisting an officer require actual knowledge that an officer is engaged in the performance of duty. The juvenile court stated: “Whether you think the police have the right to detain you or stop you or hold onto you, the law in this state says you don’t get to resist” and sustained the allegations. The court of appeal affirmed, finding the judge's comment not so ambiguous as to require reversal. The court may have found that the statutes were violated so long as the officers were performing their duty, without regard to A.L.’s awareness of that fact, or may have been referring only to section 243(b) and correctly describing the law. The court expressly found that the necessary elements for all three offenses had been proven beyond a reasonable doubt; those elements include the actual knowledge requirement of sections 69 and 148(a)(1). View "In re A.L." on Justia Law

E.C. alleged she was sexually assaulted on the premises of Pass Christian High School. The Youth Court adjudicated the alleged perpetrators not delinquent. Later, Roy and Kimberly Cuevas, individually, and on behalf of their minor daughter, E.C., filed a negligence action seeking damages from the Pass Christian School District associated with the alleged assault. Pass Christian unsuccessfully sought the records from the youth-court action to use in its defense in the civil case. It argued on appeal that the youth-court judge abused her discretion in denying its requests for disclosure of the youth-court records and trial transcripts relating to the three minor perpetrators. It also argued it would be denied due process and fairness if the sworn testimony of E.C. were not released due to the confidentiality rules protecting the subjects of youth-court actions. The Mississippi Supreme Court reversed and remanded for the circuit court to conduct an in camera review of the youth-court record to determine whether any of it should have been disclosed. View "In the Interest of M.D.G. v. Harrison County Youth Court of Mississippi" on Justia Law

At issue in this case was a Family Court order adjudging appellant Joseph Baker, Jr., a minor child, delinquent for having committed an act of Rape in the Second Degree. Initially, Baker was charged with three counts of Rape in the Second Degree. Count Two was voluntarily dismissed by the State before trial. At trial, the Family Court judge found Baker delinquent on Count One and acquitted him on Count Three. On appeal, Baker argued the judgment of delinquency for the one count of Rape in the Second Degree should be reversed because of evidentiary errors made by the Family Court judge at trial. The Delaware Supreme Court agreed that errors were made and reversal was required. View "Baker v. Delaware" on Justia Law

Minor J.S. appealed a dispositional order adjudging him a ward of the court pursuant to Welfare and Institutions Code section 602 and placing him on formal probation, subject to various terms and conditions. At the time of the incident that led to the charges against J.S., in October 2017, the victim, John Doe, was nine years old and lived with his grandmother in Contra Costa County, California. That month, a family friend and her son and two nephews, 12-year-old J.S. and his brother R.R., were temporarily staying at Doe's home. The family friend's nephews stayed in Doe's room with him. Doe woke up and turned on the light in his room. At that time, R.R. was still sleeping and J.S. was in the bathroom getting ready for school. When J.S. returned to the bedroom, he told Doe to suck his "private part," and said that if Doe did not do it, J.S. would hurt Doe. J.S. exposed his penis and "showed" Doe what he wanted Doe to do. Doe was afraid that J.S. would hurt him, so he got on the ground and began to orally copulate J.S. Doe's grandmother discovered the pair; police were ultimately called. J.S. denied the sequence of events. On appeal, J.S. argued that certain probation conditions that permitted searches of his electronic devices and imposed limitations on his use of computers, the Internet, and social networking Web sites were unconstitutionally overbroad and should be stricken in their entirety. In the alternative, J.S. contended that the conditions at issue should have been stricken and the case remanded to allow the trial court to determine whether the conditions can be narrowly tailored to serve the state's interest in rehabilitation. Finding no abuse of discretion or other reversible error, the Court of Appeal affirmed. View "In re J.S." on Justia Law

Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law

The State of New Jersey charged fourteen-year-old D.M. with delinquency based on conduct which, if committed by an adult, would constitute first-degree aggravated sexual assault. The State alleged D.M. committed acts of sexual penetration against an eleven-year-old acquaintance, Z.Y. With the parties’ consent, the Family Part judge considered the lesser-related charge of third-degree endangering the welfare of a child. In this appeal, the issue presented for the New Jersey Supreme Court's review centered on whether a juvenile could be adjudicated delinquent for endangering the welfare of a child when the juvenile and his alleged victim were fewer than four years apart in age and the Family Part judge made no findings of sexual penetration, force, or coercion. An Appellate Division panel reversed the juvenile adjudication, reasoning that the Legislature did not intend for the endangering statute, N.J.S.A. 2C:24-4(a)(1), to support a delinquency adjudication based on a juvenile’s sexual contact with another minor fewer than four years younger than he, in the absence of a finding of sexual penetration, force, or coercion. The New Jersey Supreme Court did not concur with the Appellate Division panel’s construction of the endangering statute. Although the Legislature may decide that statute: "nothing in the current text of N.J.S.A. 2C:24-4(a)(1) precludes the adjudication in this case. We decline to rewrite the statute’s plain language in this appeal." The Court concluded, however, that the Family Part court’s adjudication had to be reversed: "When the court, at the disposition hearing, disavowed critical aspects of its previously-stated factual findings and characterized its decision to adjudicate D.M. under the lesser-related offense as a humanitarian gesture, it undermined its determination as to both offenses. In this extraordinary setting, it is unclear whether the State met its burden to prove beyond a reasonable doubt that D.M. violated N.J.S.A. 2C:24-4(a)(1)." View "New Jersey in the Interest of D.M." on Justia Law

The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err.Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law