Justia Juvenile Law Opinion Summaries

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

Relying on Idaho Criminal Rule 47, Jane Doe filed a motion to modify disposition requesting that the juvenile court place her back on probation after sentence had been imposed, and modify its previous computation of credit for time served. The juvenile court held that Doe’s motion was actually a motion to reduce sentence under Idaho Criminal Rule 35 (a rule which has not been incorporated into the Idaho Juvenile Rules) and concluded that it did not have jurisdiction to consider Doe’s motion. Doe appealed the juvenile court’s decision to the district court. The district court affirmed the decision, holding that Rule 47 did not grant jurisdiction to reduce the sentence, but that jurisdiction existed under Idaho Code sections 20-505 and 20-507. The district court held that whether the sentence should be modified was a discretionary call and that the juvenile court did not abuse its discretion in declining to place Doe back on probation or incorrectly calculate Doe’s credit for time served. The Idaho Supreme Court agreed with the district court’s decision to affirm the magistrate court’s denial of Doe’s motion to modify disposition, but took the opportunity to explain there was no jurisdiction for the juvenile court to modify the juvenile’s sentence once it had been imposed and the time for appeal had run. View "Idaho v. Jane Doe (Juvenile)" on Justia Law

The Court of Appeals reversed the judgment of the Court of Special Appeals vacating in part the juvenile court's order and determining that the juvenile court erred in ordering $65 in restitution to rekey three household locks where the corresponding keys were stolen during an armed robbery, holding that, pursuant to the "direct result" requirement of Md. Crim. Proc. (CP) 11-603(a), the restitution award was proper.G.R. pleaded involved to charges of robbery, second-degree assault, and openly carrying a dangerous weapon. The circuit court found G.R. liable for $120 in restitution, including $65 to rekey the locks of three homes of which the keys were stolen. The Court of Appeals vacated the restitution order, concluding that the costs of rekeying the locks was not a direct result of the underlying robbery. The Court of Appeals reversed, holding that G.R.'s robbery directly resulted in a substantial decrease of value of the locks because it brought into question the underlying security of the homes the stolen house keys belonged to, and therefore, the decision to rekey the locks was not an intervening act but a necessary action taken to maintain the security of the homes to which the keys belonged. View "In re G.R." on Justia Law

Minor, age 16, admitted to carjacking with a personal firearm use enhancement. The probation officer recommended the juvenile court adjudge Minor a ward of the court; remove him from parental custody; commit him to a county institution for a period not to exceed maximum custody time of 12 years, or until age 21, whichever occurs first; and that the court order Minor to participate in the County Institution Program, YOTP [Youthful Offender Treatment Program] and successfully complete all phases, follow all treatment requirements, and obey all rules. Over defense counsel’s objection, the court adopted the recommendation of YOTP commitment, “to meet [Minor’s] rehabilitative needs while keeping the community safe.” The court concluded that a lesser restrictive alternative would not be appropriate and declined to order a fixed term. The court noted that if Minor completed a “perfect” YOTP program, he would be held for about 10 months; otherwise, the maximum period would be until his 21st birthday. The court set a “YOTP review date” for December 2018, seven months away. The court of appeal affirmed the order, rejecting Minor’s contention that it impermissibly delegates to the probation officer the authority to determine the length of commitment. At review hearings, Minor may inform the juvenile court if he disagrees with the assessment of his progress. View "In re J.C." on Justia Law

The Supreme Court reversed the judgment of the Court of Appeal upholding the juvenile court's finding that H.W. possessed an "other instrument or tool with intent feloniously to break or enter" within the meaning of Cal. Penal Code 466, holding that the pair of pliers that H.W. was in possession of when he was apprehended were not an "other instrument or tool" within the meaning of section 466.H.W., a minor, entered a Sears department store with the intent to steal a pair of jeans. When H.W. was apprehended and searched, he had in possession the jeans and a pair of pliers approximately ten inches in length, with a half-inch blade. The juvenile court sustained the burglary tool possession allegation brought against H.W. The Court of Appeal upheld the juvenile court's determination. The Supreme Court reversed, holding (1) the record did not support the conclusion that H.W. intended to use the pliers to do anything other than remove the anti-theft tag from the jeans; and (2) therefore, there was insufficient evidence to support the section 466 allegation. View "In re H.W." 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 the circuit court erred in sentencing Appellant under the FSMA because Appellant committed his crime before the effective date of the FSMA.In 1996, Appellant was convicted of capital murder and received a mandatory sentence of life imprisonment without parole. Appellant was sixteen years old at the time of the crime. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant filed a petition for writ of habeas corpus. The circuit court issued the writ, vacated Appellant's sentence, and remanded the case for resentencing. Before Appellant's resentencing hearing was held, 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. The circuit court retroactively applied the FSMA to Appellant and resentenced him to life imprisonment with the possibility of parole after thirty years. The Supreme Court reversed and remanded for a resentencing hearing, holding that Harris v. State, 547 S.W.3d 64, controls this appeal and that the circuit court erred by sentencing Appellant under the FSMA. View "Miller v. State" on Justia Law