Justia Juvenile Law Opinion Summaries

Appellant Anthony Machicote argued his sentence was illegal because he was subject to a potential sentence of life without parole, and prior to imposing his sentence, the trial court did not consider the factors enumerated in Miller v. Alabama, 567 U.S. 460 (2012), as adopted by the Pennsylvania Supreme Court in Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (Batts I) and Commonwealth v. Batts (Batts II), 163 A.3d 410 (Pa. 2017). In 2003, Appellant was 17 years old and a resident at George Junior Republic, a residential treatment facility for at-risk youth. Appellant and a co-resident, Jeremy Melvin, devised a plan to subdue a night supervisor at the facility in order to escape. Appellant called the night supervisor, Wayne Urey, Jr., to his room. Melvin, who was hiding, attacked Urey from behind, put him in a chokehold, and brought him to the ground. Appellant and Melvin bound and gagged Urey, and proceeded to steal his keys, wallet, and truck. Appellant and Melvin escaped, and Urey ultimately died of suffocation. Appellant and Melvin turned themselves in later that same day. Appellant was charged with homicide, robbery, and related offenses. Appellant pled guilty to second-degree murder and the remaining charges were dismissed. Appellant was sentenced to life without the possibility of parole. Appellant did not appeal his sentence. The Superior Court concluded that Appellant’s challenge to his sentence was moot because he was ultimately not sentenced to life without the possibility of parole. The Supreme Court concluded the issue was not moot, and the trial court erred when it failed to consider the Miller factors on the record when it resentenced Appellant. View "Pennsylvania v. Machicote" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and the order denying his motion for a new trial, holding that Defendant's sentence was constitutional and that no prejudicial error occurred in the proceedings below.Defendant, who was seventeen years of age at the time of the murder, was sentenced to a mandatory term of life imprisonment with eligibility for parole after fifteen years. The Supreme Judicial Court disagreed, holding (1) a mandatory life sentence with parole eligibility after fifteen years for a juvenile homicide offender convicted of murder in the second degree is constitutional; (2) the judge did not err in denying Defendant's motion to continue his sentence so that he could present evidence related to his juvenile status; (3) the judge did not err in denying Defendant's request to instruct the jury on accident; (4) Defendant's counsel was not ineffective for not requesting other jury instructions; and (5) the judge did not err in denying Defendant's motion to suppress the warrantless "pinging" of Defendant's cellular telephone because no evidence came from the search. View "Commonwealth v. Lugo" on Justia Law

A jury found defendant guilty of four counts of first-degree murder (720 ILCS 5/9-1(a)(1), (a)(2)), and specifically found that defendant, age 16 at the time of the crime, personally discharged a firearm that caused the victim’s death. Defendant was sentenced in 2010. Illinois law then prescribed a sentencing range of 20-60 years for first-degree murder (730 ILCS 5/5-4.5-20(a)) and mandated a minimum 25-year additional term for personally discharging a firearm that caused the victim’s death. The court stated that it “considered all of the relevant statutory requirements," merged the counts, and sentenced defendant to 25 years on the murder conviction and 25 years for the mandatory firearm add-on.While defendant’s appeal was pending, the U.S. Supreme Court held (Miller v. Alabama) that imposing on a juvenile offender a mandatory sentence of life without the possibility of parole, without consideration of the defendant’s youth and its attendant characteristics, violated the Eighth Amendment. The appellate court denied defendant leave to file a supplemental brief, then affirmed defendant’s conviction and sentence. The Illinois Supreme Court subsequently held that Miller applied retroactively to cases on collateral review. Defendant filed a pro se postconviction petition, which the circuit court summarily dismissed as frivolous. While defendant’s appeal was pending, the U.S. Supreme Court held that Miller applied retroactively to cases on collateral review; the Illinois Supreme Court extended Miller’s holding to mandatory de facto life sentences. The Illinois Supreme Court affirmed a remand for resentencing. Defendant’s sentence was greater than 40 years and constituted a de facto life sentence. The circuit court failed to consider defendant’s youth and its attendant characteristics in imposing that sentence. View "People v. Buffer" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), holding that because Appellant had his sentence vacated pursuant to Miller v. Alabama, 567 U.S. 460 (2012), Appellant was not subject to sentencing under the FSMA.Appellant was convicted of capital murder for an offense he committed when he was less than eighteen years of age. The jury sentenced Appellant to life imprisonment without the possibility of parole. Appellant's sentence was later vacated pursuant to Miller. Before the resentencing hearing, the Arkansas General Assembly passed the FSMA. The circuit court sentenced Appellant under the FSMA to a term of life imprisonment with the possibility of parole after thirty years. After the circuit court's order, the Supreme Court decided Harris v. State, 547 S.W.3d 64, in which the Court determined that individuals who had their sentences vacated pursuant to Miller were not subject to sentencing under the FSMA. On appeal, Appellant argued that his case should be controlled by Harris even where Harris was handed down after the circuit court's ruling. The Supreme Court agreed and remanded the case for resentencing in accordance with Harris. View "Williams v. State" on Justia Law

Chioma and Edwards were each convicted on multiple counts arising from their joint 2012 sexual assault and robbery of Jane Doe and robbery of her male friend. With “one-strike” (because they inflicted great bodily injury and personally used a firearm) and other allegations against them, Chioma was sentenced to 129 years to life, and Edwards was sentenced to 95 years to life. Both were 19 years old when they committed these offenses. They challenged their prison sentences as cruel and unusual punishment, and, on equal protection grounds, challenged their exclusion from the Section I. 2 provisions of Penal Code section 30511—which mandates youthful-offender parole hearings for most who receive de facto life sentences for crimes they commit at or before age 25. The court of appeal rejected the’ cruel and unusual punishment challenge but accepted their equal protection arguments and remanded to allow the development of the record with evidence of youth-related factors that will be relevant in a youthful-offender parole hearing. Under the One-Strike exemption to Penal Code 30511, an entire class of youthful offenders convicted of crimes short of homicide is, regardless of criminal history, categorically exempted from an opportunity offered to all youthful first degree murderers except those sentenced to life without the possibility of parole. View "People v. Edwards" on Justia Law

The juvenile defendant committed a misdemeanor for disturbing the peace on school grounds after he called a teacher, who was trying to stop a fist fight involving defendant, a racial slur. The juvenile court judge granted probation on several conditions, including the condition that defendant's electronic devices would be subject to search.The court affirmed the trial court's condition requiring defendant to consent to a search of electronic devices as a correctional tool in defendant's reformation and rehabilitation. The court held that the electronic search condition was reasonable because it allowed law enforcement to monitor defendant's compliance with conditions of his probation and the condition was not overbroad where it limited the search to specific forms of digital communication. View "People v. J.G." on Justia Law

In 1992 when Jeremiah Gilbert was a juvenile, he was charged and convicted of aggravated murder, premeditated murder, and multiple other crimes. He was sentenced to life without parole for the aggravated murder along with a consecutive sentence for the premeditated murder, as required under the laws in effect at that time. When RCW 10.95.035 was enacted, Gilbert became entitled to a new sentencing hearing. During his resentencing, Gilbert argued that the judge should restructure his two sentences such that they would run concurrently. However, the judge ruled that he lacked Statutory authority to address anything other than Gilbert's sentence for aggravated murder and imposed a sentence of 25 years to life, leaving intact the consecutive sentence of 280 months for the premeditated murder conviction. The Court of Appeals affirmed. The Washington Supreme Court found that because the judge presiding over Gilbert's resentencing believed he did not have discretion to consider anything other than an adjustment to the aggravated murder sentence, he did not consider whether the mitigating factors of Gilbert's youth might warrant an exceptional sentence. The Court found this to be error: Gilbert was entitled at his resentencing to consideration of an exceptional sentence in light of the potential mitigating factors of his youth. Therefore, the Supreme Court reversed and remanded for that consideration. View "Washington v. Gilbert" on Justia Law

At age 13, petitioner Conrad Slocumb kidnapped and sexually assaulted a teacher before shooting her in the face and head five times and leaving her for dead. Three years later, following his guilty plea for the first set of crimes, he escaped from custody and raped and robbed another woman in a brutal manner before being apprehended again. For these two sets of crimes, Slocumb received an aggregate 130-year sentence due to the individual sentences being run consecutively. Before the South Carolina Supreme Court, Slocumb argued an aggregate 130-year sentence for multiple offenses committed on multiple dates violated the Eighth Amendment to the United States Constitution. The South Carolina Court acknowledged the “ostensible merit in Slocumb's argument, for it is arguably a reasonable extension of Graham [v. Florida, 560 U.S. 48 (2010)] and Miller [v. Alabama, 567 U.S. 460 (2012)]. Yet precedent dictates that only the Supreme Court may extend and enlarge the protections guaranteed by the United States Constitution. Once the Supreme Court has drawn a line in the sand, the authority to redraw that line and broaden federal constitutional protections is limited to our nation's highest court.” Because the decision to expand the reach and protections of the Eighth Amendment lay exclusively with the Supreme Court, the South Carolina Supreme Court felt constrained to deny Slocumb relief. View "South Carolina v. Slocumb" on Justia Law

E.F. pleaded guilty to a number of federal offenses pursuant to a plea agreement. Under the terms of the agreement, the government agreed that it would recommend a sentence below the one recommended by the United States Sentencing Guidelines. As a result of that agreement, the district court significantly reduced E.F.’s advisory guidelines range to approximately half the term of imprisonment recommended by the Guidelines. E.F. was ultimately sentenced to the mandatory minimum sentence. The district court noted it would have preferred to sentence E.F. to a lesser sentence, but it was unable to do so in light of the government’s refusal to file a motion for a further reduction pursuant to 18 U.S.C. 3553(e). On appeal of the sentence, E.F. argued: (1) the government breached the covenant of good faith and fair dealing implied in the plea agreement when it refused to file a 3553(e) motion; (2) the government’s refusal was not rationally related to a legitimate government end and that enforcing the plea agreement would result in a miscarriage of justice; and (3) the sentence was substantively unreasonable. The district court first considered whether United States v. Doe, 865 F.3d 1295 (10th Cir. 2017), applied. The court concluded that while Doe applied, E.F. failed to satisfy the Doe requirements that would trigger good-faith review by the district court. Thus, the plea agreement was not subject to good-faith review. The Tenth Circuit concurred with the district court’s analysis under Doe and affirmed its conclusion that the government’s decision not to file a 3553(e) motion was not subject to good-faith review. View "In re: Sealed Opinion" on Justia Law

Petitioner filed suit challenging the Director's repeated denial of parole to petitioner. The district court granted the Director's motion to dismiss, holding that juvenile-specific Eighth Amendment protections do not apply to petitioner because he was sentenced to life with parole, and that the Parole Board procedures satisfied procedural due process requirements under the Fourteenth Amendment.Reading petitioner's 28 U.S.C. 2254 petition as a 42 U.S.C. 1983 complaint, the Fourth Circuit declined to extend the Supreme Court's Eighth Amendment jurisprudence to juvenile parole proceedings and find that it is cruel and unusual punishment for a parole board to deny juvenile offenders parole without specifically considering age-related mitigating characteristics as a separate factor in the decisionmaking process. In regard to the Fourteenth Amendment claim, the court held that, although there was no constitutional or inherent right to parole proceedings, Virginia law gives rise to an expectation of parole proceedings that has created a liberty interest in parole consideration. The court held that, nevertheless, to satisfy the due process requirements triggered by this liberty interest, a parole board need only provide an offender an opportunity to be heard and a statement of reasons indicating why parole has been denied. In this case, petitioner's parole proceedings satisfied those requirements. View "Bowling v. Director, Virginia Department of Corrections" on Justia Law