Justia Juvenile Law Opinion Summaries

While on juvenile parole related to a commitment to Oregon Youth Authority (OYA) in an earlier case, B.Y. was adjudicated to be within the jurisdiction of the juvenile court for interfering with a peace officer. Based on that conduct, the juvenile court imposed a new disposition, which also committed B.Y. to OYA custody, to commence at the conclusion of his existing commitment. B.Y. challenged that order, contending that the juvenile court lacked authority to impose consecutive commitments. A divided panel of the Court of Appeals agreed with B.Y. and reversed the juvenile court. The Oregon Supreme Court reversed the appellate court: “the statutory text neither expressly permits nor expressly prohibits the imposition of consecutive commitments. The statutory scheme does, however, confer broad authority on the juvenile court to fashion appropriate dispositions; that stands in contrast to the criminal code, where courts’ sentencing authority is more circumscribed. Given that contrast, the fact that the legislature did not explicitly provide for consecutive commitments in a circumstance such as this is unsurprising. In light of the wide latitude that the legislature has chosen to give juvenile courts, it is more reasonable to expect that if the legislature had intended to limit the juvenile court’s ability to impose consecutive commitments in this circumstance, the legislature would have indicated as much.” View "Oregon v. B. Y." on Justia Law

The Supreme Court affirmed the order of the district court denying the motion filed by H.M., a youth held in detention, seeking to dismiss a formal petition brought by the State to adjudicate H.M. as a delinquent youth, alleging one count of misdemeanor resisting arrest and three counts of assault on a police officer, holding that the district court did not err in denying the motion.As grounds to dismiss the petition H.M. argued that the State filed it one day beyond the seven-day time limit for such petitions against detained youths in Mont. Code Ann. 41-5-1401(2). The youth court declined to dismiss the petition, concluding that the State had good cause to file the petition and to detain H.M., outside the seven-day deadline. The Supreme Court affirmed, holding (1) the good cause exception in section 41-5-1401(2) applies to the youth court's decision not to dismiss an untimely petition charging a youth held in detention; and (2) the youth court properly denied H.M.'s motion to dismiss. View "In re H.M." on Justia Law

At age 16, defendant Tory Bratton confessed to robbing a local market, with an accomplice, shooting the clerk dead, and taking $184. At his trial, his counsel argued that defendant’s confession was false and that he did not participate in the robbery at all. However, trial counsel did not argue that, even if defendant did participate, he was not the shooter. Defendant was convicted of (among other things) first degree murder, with a personal firearm use enhancement and felony-murder special circumstances. He appealed; the Court of Appeal affirmed. When defendant filed a petition to vacate the murder conviction under Penal Code section 1172.6, the trial court denied it; it ruled that the Court of Appeal's opinion in defendant’s direct appeal showed that he was the actual killer. The State conceded that this was error, but that the error was harmless because the record of conviction established defendant was the actual killer. Anticipating this response, defendant argued that, under standard principles of issue preclusion (a/k/a collateral estoppel), preclusion did not apply here because: (1) Whether defendant was the shooter was not actually litigated; (2) Trial counsel had an incentive not to contest whether defendant was the shooter; (3) The significance of whether defendant was the shooter was small at trial but, due to the then-unforeseeable enactment of section 1172.6, has since become great; (4) Section 1172.6 was a significant change in the law that warranted reexamination of whether defendant was the shooter. The Court of Appeal agreed that standard principles of issue preclusion applied here. However, the Court held that the issue of whether defendant was the shooter was actually litigated. Moreover, trial counsel did have an incentive to contest this issue; evidently, he simply made a tactical decision not to. Because trial counsel did have an incentive to contest the issue, it did not matter that it was unforeseeable that the issue would have additional future consequences. And finally, while section 1172.6 was a significant change in the law, the Legislature intended that it not constitute an exception ipso facto to issue preclusion. View "California v. Bratton" on Justia Law

Michael Reynolds Jr. received a mandatory sentence of life in prison without possibility of parole for a crime he committed at age 33. The events triggering that sentence, though, were his two “strikes” under Washington’s “three strikes” law—one of which Reynolds committed at age 17, when he was a juvenile. If Reynolds’ current sentence constituted punishment for his earlier offense committed at age 17, then it would be unconstitutional under case law. But under the Washington Supreme Court’s more recent precedent, his current sentence did not constitute punishment for that prior offense. In Washington v. Moretti, decided two years after Bassett, the Supreme Court held that a “three strikes” sentence of mandatory life in prison without possibility of parole constituted punishment for the last crime or third “strike,” not the earlier first or second “strikes.” “And for years, we have held that our state’s ‘three strikes’ law as applied to adults does not violate article I, section 14.2 That assessment could certainly change over time. But in this case, the parties have not asked us to overrule it.” The Court therefore affirmed the Court of Appeals. View "Washington v. Reynolds" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court ordering A.R., who was adjudicated delinquent in a proceeding under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-5042, detained in a juvenile institution until he reached the age of twenty-one, followed by a term of juvenile delinquent supervision, holding that remand was required.A.R., who was born in 2003, was adjudicated delinquent pursuant to his admission of aiding and abetting an attempted robbery of a motor vehicle and five carjackings, each of which would have been a violation of 18 U.S.C. 2119 had A.R. been an adult. On appeal, A.R. primarily challenged the district court's order of a detention period rather than a probationary one. The First Circuit affirmed as to the court's imposition of detention but reversed and remanded as to two other matters, holding (1) A.R.'s disposition was both procedurally and substantively reasonable; (2) the district court erred in failing to recommend that A.R. be placed in a local detention facility; and (3) the district court erred in imposing a term of detention and supervision that together exceeded the applicable statutory maximum. View "United States v. A.R." on Justia Law

Petitioner Robert Miller, III was convicted of murdering eighty-six-year-old Willie Johnson. Following the murder, Petitioner—who was fifteen years old at the time—confessed four times: twice to his close friends and twice to law enforcement. All four confessions were admitted at trial, three without objection. This appeal centered around the voluntariness of Petitioner's fourth and final confession to two agents of the South Carolina Law Enforcement Division (SLED). After examining the totality of the circumstances surrounding the fourth confession, the South Carolina Supreme Court held that Petitioner's free will was not overborne, and his confession was voluntary. It therefore affirmed. View "South Carolina v. Miller" on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

The Supreme Court reversed the judgment of the district court denying Appellant's motion to transfer his criminal case to youth court, holding that the district court abused its discretion by failing to consider Appellant's mitigating and unrequited evidence supporting transfer.Defendant had turned seventeen years old one month before the incident leading to his charges of sexual intercourse without consent, sexual abuse of children, and sexual assault. After a hearing to determine if the case should be transferred to youth court, the district court concluded that transferring the case would be in Defendant's best interests and would serve the interests of community protection but that the transfer should be denied based on the severity of the offense. The Supreme Court reversed, holding that the district court misapprehended the evidence presented by Defendant suggesting that the nature of the offense did not warrant district court prosecution and, instead, impermissibly reached its conclusion based solely on the egregious facts of the offense. View "State v. Johnson" on Justia Law

In the midst of a group contacted by officers for smoking cannabis on the street, 16-year-old T.F.-G. witnessed first one and then another of his companions be restrained, searched, and made to sit on the curb as the officers worked their way through the group. T.F.-G. ran. Chased, tackled, and punched, he was arrested for resisting or delaying a peace officer (Pen. Code 148(a)). In a search incident to that arrest, the police found a loaded handgun in his pocket, which T.F.-G. was not licensed to carry.The court of appeal affirmed his convictions. The totality of the circumstances, establishing the existence of probable cause for his arrest for resisting or delaying a peace officer—the asserted basis for the eventual search that revealed his possession of a loaded handgun in public–indicated that a reasonable person in T.F.-G.’s position would have understood he was not free to leave. The court also rejected a Second Amendment facial challenge to the prohibition on the unlicensed public carrying of loaded firearms. Although California’s “good cause” licensing requirement is undisputedly unconstitutional under the Supreme Court’s 2022 “Bruen” decision, the unconstitutionality of a discrete licensing requirement does not render section 25850 facially unconstitutional. View "In re T.F.-G." on Justia Law

After adjudicating A. H. delinquent, but finding that he was not in need of treatment, rehabilitation, or supervision, the juvenile court in this case entered an order dismissing the delinquency proceedings under OCGA § 15-11-600 (d) and sealing the record under OCGA § 15-11-701. The State appealed the juvenile court’s decision to seal the record, but the Court of Appeals dismissed the appeal, concluding that neither OCGA § 5-7-1(a)(1) nor OCGA § 5-7-1(a)(6) authorized the State to appeal the juvenile court’s order. The Georgia Supreme Court granted certiorari to determine whether “the Court of Appeals err[ed] in concluding that the State was not permitted to appeal under OCGA § 5-7-1(a).” The Supreme Court found with respect to subsection (a)(6), the issue was neither fully litigated below nor briefed by the parties in significant depth to the Supreme Court. "Thus, although this issue is properly before us in a narrow sense, it is not presented in a form that would allow us to clarify the law or otherwise provide meaningful guidance." Accordingly, the writ was vacated, and the petition for certiorari in Case No. S22C1035 was denied. View "In the Interest of A.H." on Justia Law