Justia Juvenile Law Opinion Summaries

Along with his twin brother, Lydell, petitioner Laycelle White was charged with and convicted of aggravated murder and murder, receiving a sentence of life with the possibility of parole for the murder of one victim and an 800-month determinate sentence for the murder of the other. At the time, petitioner was 15 years old. In a petition for post-conviction relief, petitioner argued the 800-month sentence for one murder was a de facto life sentence without parole that had to comport with the United States Supreme Court’s decision in Miller v. Alabama, 567 US 460 (2012). Petitioner argued the record in this case, decided 17 years before Miller, did not establish that the trial court made the required “irreparable corruption” finding and that his sentence therefore was invalid. The Oregon Supreme Court agreed with this reasoning and reversed the decisions of the Court of Appeals, and of the post-conviction court, and remanded to the post-conviction court for further proceedings. View "White v. Premo" on Justia Law

In this post-conviction proceeding, petitioner Lydell White, a juvenile offender, was convicted along with his twin brother Laycelle for aggravated murder and murder. He contended on petition for post-conviction relief that the 800-month sentence he was serving for a single homicide was the functional equivalent of life without parole and was imposed without a hearing that satisfied the procedural and substantive requirements of the Eighth Amendment. The Oregon Supreme Court agreed, finding petitioner was not procedurally barred from seeking post-conviction relief, and that his sentence was subject to the protections of Miller v. Alabama, 567 US 460 (2012). “Because this record does not convince us that the sentencing court determined that petitioner’s crime reflects irreparable corruption, we reverse the decisions of the Court of Appeals and the post-conviction court and remand to the post-conviction court for further proceedings.” View "White v. Premo" on Justia Law

A juvenile challenged his suspended manifest injustice disposition. The Court of Appeals dismissed his claim on ripeness grounds; the juvenile disagreed his claim was not yet ripe. Furthermore, the juvenile argued the trial court applied the wrong standard of proof during his sentencing hearing, and as a result, improperly imposed the manifest injustice disposition. The juvenile was convicted on two counts of unlawful imprisonment with sexual motivation, and one count of fourth degree assault without sexual motivation. Since he had no prior criminal history, the State recommended, and the trial court adopted, a manifest injustice disposition of 36 weeks' confinement to be suspended by a special sex offender disposition alternative (SSODA). The parties to this case agreed this case was moot, given the juvenile served his sentence by the time the matter reached the Washington Supreme Court. However, finding the issue presented was one of "continuing and substantial interest," the Washington Supreme Court considered the case, determining that the appropriate standard of proof, as found in controlling Washington case law, was "clear and convincing," or the civil equivalent of the criminal standard of beyond a reasonable doubt. The Supreme Court held manifest injustice dispositions suspended by SSODA are reviewable when imposed - juveniles do not need to wait for the disposition to be executed before challenging it. Therefore, the Court of Appeals' ruling to the contrary was overturned. The Court affirmed the juvenile's conviction and sentence. View "Washington v. T.J.S.-M." on Justia Law

The juvenile court found E.P. committed second degree burglary, possessed graffiti tools, received stolen property, and illegally possessed an alcoholic beverage. The Court of Appeal initially concluded that the evidence was insufficient to show that E.P. committed burglary when he stole items from locker rooms in a public ice hockey facility because the prosecution failed to prove that E.P. did not commit the new crime of shoplifting, as defined in Proposition 47. Because E.P. was not charged with shoplifting, the Court also concluded there was no bar to charging him with receiving stolen property. After the Court of Appeal issued its opinion, the California Supreme Court in California v. Colbert, 6 Cal.5th 596 (2019), held that “entering an interior room that is objectively identifiable as off-limits to the public with intent to steal therefrom is not shoplifting, but instead remains punishable as burglary.” The Supreme Court transferred the matter to the Court of Appeal with directions to vacate its decision and reconsider the case in light of Colbert. After review, the appellate court found Colbert did not change its conclusion that the prosecution failed to prove E.P. committed burglary. The evidence showed the locker rooms of the public ice hockey facility were not “objectively identifiable as off-limits to the public.” Accordingly, the Court reversed the finding E.P. committed burglary, but affirmed the findings he received stolen property and illegally possessed an alcoholic beverage. View "In re E.P." on Justia Law

The Supreme Court reversed the circuit court's order denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing with Minors Act of 2017 (FSMA), holding that the penalty provisions of the FSMA did not apply to Appellant.In 2000, Appellant pled guilty to capital murder and received a mandatory sentence of life in prison without parole. Appellant was sixteen years old at the time of the murder. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), the circuit court granted habeas relief and vacated Appellant's life-without-parole sentence and remanded his case for resentencing. Before a resentencing hearing was held, however, the General Assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders and extended parole eligibility to juvenile offenders. On remand, the circuit court sentenced Appellant under the FSMA to life in prison with parole eligibility after thirty years. The Supreme Court reversed, holding (1) because Appellant committed his crime before the effective date of the FMSA, the penalty provisions of the Act did not apply to him; and (2) Appellant was no longer serving a sentence to which parole eligibility could attach. View "Elliott v. State" on Justia Law

Penal Code section 1170.95's petitioning procedure applies to a juvenile, like the one in this case, whose murder allegation was sustained by the juvenile court on a natural and probable consequences theory prior to the enactment of Senate Bill 1437, which amended the natural and probable consequences doctrine as it relates to murder. Because R.G. has not petitioned the court to have the conviction vacated and the corresponding commitment recalled, the Court of Appeal held that Senate Bill 1437 relief was premature. Accordingly, the court affirmed the juvenile court's order sustaining the allegation that R.G. committed second degree murder. View "People v. R.G." on Justia Law

Time Rikat Meippen was a juvenile when he was convicted in adult court of first degree assault, first degree robbery, and second degree unlawful possession of a firearm. The trial court sentenced Meippen to the top of the standard sentencing range and imposed a firearm sentence enhancement. Several years after Meippen's sentencing, the Washington Supreme Court decided Washinton v. Houston-Sconiers, 391 P.3d 409 (2017). Meippen subsequently filed an untimely personal restraint petition (PRP), arguing that Houston-Sconiers constituted a significant and material change in the law that should apply retroactively. Even assuming Meippen could show that Houston-Sconiers was a significant, material change in the law that applied retroactively, the Supreme Court held he was not entitled to collateral relief because he did not demonstrate that any error actually and substantially prejudiced him: the trial court had the discretion to impose a lesser sentence under the Sentencing Reform Act, at the time, and instead sentenced Meippen at the top of the sentencing range. View "In re Pers. Restraint Petition of Meippen" on Justia Law

A jury found defendants Luis Alberto Ramirez and Jose Roberto Armendariz committed two gang-related murders when they were juveniles. The trial court originally sentenced Ramirez to life without the possibility of parole, plus 65 years to life, and it sentenced Armendariz to 90 years to life. Eventually, the Court of Appeal reversed the sentences and remanded the matter to the trial court for resentencing. Following remand, Proposition 57 was enacted. The California Supreme Court held Proposition 57 applied retroactively to all cases not yet final at the time it was enacted. Thereafter, defendants filed a motion requesting the superior court remand their case to the juvenile court per Proposition 57. Over the prosecutor’s objections, the court granted the motion and ordered the matter transferred to the juvenile court. The District Attorney sought review of the trial court’s transfer order via writ and direct appeal. The Court of Appeal summarily denied the District Attorney’s petition for a writ of mandate or prohibition, leaving only this appeal. Defendants moved to dismiss the instant appeal, contending the trial court’s transfer order was not appealable. The Court of Appeal denied: "Notwithstanding the fact this court reversed defendants’ sentences, the transfer order is appealable under Penal Code section 1238 (a)(5), as an 'order made after judgment, affecting the substantial rights of the people.'” Judgments were entered when the initial sentences were imposed. While the sentences were reversed and resentencing ordered, the resentencing would result in modified judgments, not new judgments. Because the transfer order affects the State's ability to enforce the modified judgements, it was appealable under Penal Code section 1238 (a)(5). On the merits, the District Attorney contended the trial court lacked authority to order the matter transferred to the juvenile court because the transfer order exceeded the scope of the remittitur; District Attorney conceded defendants were entitled to the benefit of Proposition 57. In light of Proposition 57 and California v. Superior Court (Lara), 4 Cal.5th 299 (2018), the Court of Appeal concluded the trial court properly transferred the matter to the juvenile court to hold a transfer hearing. View "California v. Ramirez" on Justia Law

Proposition 57, enacted by voters in 2016, eliminated a district attorney’s ability to “direct file” charges in criminal court against minors who were 14 years of age or older at the time of their alleged crimes. Proposition 57 requires a district attorney to obtain juvenile court approval before prosecuting minors in criminal court. In 2018, the Legislature further restricted a district attorney’s ability to treat minors as adults by enacting Senate Bill 1391, which prohibits the transfer of 14- and 15-year-old offenders to criminal court in almost all circumstances. The Solano County District Attorney argued the new law is invalid because it is inconsistent with and does not further the intent of Proposition 57. The court of appeal disagreed and denied mandamus relief. SB 1391 takes Proposition 57’s goal of promoting juvenile rehabilitation one step further by ensuring that almost all who commit crimes at the age of 14 or 15 will be processed through the juvenile system and in no way detracts from Proposition 57’s stated intent that, where a juvenile transfer decision must be made, a judge rather than a prosecutor must make the decision. View "People v. Superior Court (Alexander C.)" on Justia Law

The Fifth Circuit vacated defendant's sentence imposed after he pleaded guilty to one count of being a felon in possession of a firearm. The court held that aggravated assault under Texas law does not categorically require the use or carrying of a knife, firearm, or destructive device, and cannot qualify as a predicate offense under Armed Career Criminal Act for juvenile adjudications. However, the district court did not err in calculating defendant's base offense level as 24 under USSG 2K2.1. The court remanded for resentencing. View "United States v. Flores" on Justia Law