Justia Juvenile Law Opinion Summaries

In 2015, the state filed a petition alleging that R.M. committed the felony-grade delinquent act of possession with intent to distribute a counterfeit controlled dangerous substance when he was 15 years old. R.M. appeared to answer the petition and entered a denial of the allegations. Pursuant to La.Ch.C. art. 877(B), the state had 90 days to commence the adjudication. R.M. filed a motion to challenge competency. The juvenile court appointed a panel of doctors to evaluate R.M. The court stayed the proceedings pursuant to La.Ch.C. art. 832 and set a competency hearing. The court, on its own motion, reset the hearing date several times after R.M. was arrested on a new charge and to give the doctors additional time to evaluate R.M. The court ultimately held the competency hearing on March 17, 2016, and found R.M. competent to proceed based on the doctors’ recommendations. The juvenile court set the adjudication for April 14, but continued the hearing until May 4 because the police officers involved in the case were not served. On May 4, 2016, the parties appeared for the adjudication, and the state made an oral motion to continue because the officers still had not been subpoenaed. In response, R.M. made an oral motion to dismiss the delinquency petition. The trial court granted R.M.’s motion, finding that the competency determination had resulted in unreasonable delay not attributable to any fault of the juvenile. The state sought supervisory review from the court of appeal, which affirmed the juvenile court’s dismissal in a split decision. The juvenile argues in essence that the state was still obligated to seek an extension for good cause, pursuant to La.Ch.C. art. 877(D), although R.M.’s competency was placed at issue and the proceedings were stayed pursuant to La.Ch.C. art. 832. The court of appeal agreed and found “that the stay pursuant to article 832 did not relieve the State of its duty to request and obtain a good cause extension before the article 877 mandatory time limit expired.” The Louisiana Supreme Court concluded the juvenile court prematurely dismissed the state’s petition. The Court reversed, finding that R.M.s’ motion to dismiss on May 4, 2016 was only 48-days in, close to a month of the 90-day period provided by La.Ch.C. art. 877 remained. View "State of Louisiana in the interest of R.M." on Justia Law

At all relevant times, minor D.P. was a ward of the court and a probationer under Welfare and Institutions Code section 602, plus he was not in custody. The prosecuting attorney, filed a subsequent section 602 petition against him not five, but 39 judicial days after receiving the affidavit from the probation officer. The trial court found that under Welfare and Institutions Code section 653.5(d), this petition was untimely and dismissed it. The State appealed. The Court of Appeal reversed: the five-day time limit of section 653.5 (d) was directory, rather than mandatory; this means that a petition filed in violation of the five-day time limit was nevertheless valid. View "In re D.P." on Justia Law

Three federal Supreme Court cases created a special category under the Eighth Amendment for juvenile offenders whose culpability was mitigated by adolescence and immaturity. "The cases recognize that a juvenile is more likely to be rehabilitated than an adult and therefore should receive a meaningful opportunity to obtain release by demonstrating maturity and rehabilitation." Petitioner Joel Ira, was sentenced as a juvenile to 91.5 years after he pled no contest to several counts of criminal sexual penetration and intimidation of a witness - crimes which he committed when he was fourteen and fifteen years old. Under the relevant New Mexico Earned Meritorious Deduction Act (EMDA), petitioner would be eligible for parole when he has served one-half of his sentence (approximately 46 years) if he maintained good behavior while incarcerated. He would be approximately 62 years old when he could first be eligible for parole. Petitioner sought habeas relief, arguing that his sentence would be cruel and unusual punishment because it amounted to a life sentence. He relied on both New Mexico and federal Supreme Court jurisprudence as grounds for relief. The New Mexico Supreme Court concluded that Graham v. Florida, 560 U.S. 48 (2010) applied when a multiple term-of-years sentence would in all likelihood keep a juvenile in prison for the rest of his or her life because the juvenile would be deprived of a meaningful opportunity to obtain release by demonstrating his or her maturity and rehabilitation. In this case, petitioner could be eligible for a parole hearing when he reached 62 years old if he demonstrated good behavior under the EMDA. Therefore, the New Mexico Court concluded petitioner had a meaningful opportunity to obtain release by demonstrating his maturity and rehabilitation before the Parole Board. View "Ira v. Janecka" on Justia Law

Iowa Code 902.1(2)(a)(1), which gives the district court the option to sentence a juvenile offender convicted of murder in the first degree to life imprisonment without the possibility of parole, is unconstitutional based on the Supreme Court’s holding in State v. Sweet, 879 N.W.2d 811 (Iowa 2016), which held that such a sentence for all juvenile offenders violates article I, section 17 of the Iowa Constitution. However, the unconstitutional portion of the statute does not render the remainder of section 902.1(2)(a) unconstitutional.Defendant was convicted of first-degree murder as a juvenile offender. Defendant challenged his sentence of life imprisonment with the possibility of parole after serving a minimum term of twenty-five years confinement. Defendant filed a motion to correct an illegal sentence, arguing that the sentencing scheme for juvenile offenders convicted of first-degree murder set forth in section 902.1(2) was cruel and unusual punishment under the Iowa Constitution. The Supreme Court held (1) section 902.1(2)(a)(1) is unconstitutional, but the remainder of section 902.1(2) is constitutional; and (2) Defendant’s case must be remanded for resentencing under State v. Roby, 897 N.W.2d 127 (Iowa 2017), which was decided subsequent to Defendant’s resentencing. View "State v. Zarate" on Justia Law

Two 16-year-old high school students got into a shouting match in the girls' bathroom. Things turned physical when Tracy Cannon threw Alcee Johnson-Franklin to the ground and started throwing punches. Alcee tried to protect herself from the blows, and the two ended up on the floor of the bathroom, grappling and kicking at each other. It was over in less than a minute, but within two hours of the assault, Alcee was pronounced dead, not from blunt-force trauma, but from a rare heart condition that even Alcee did not know she had. This tragic result prompted the State to charge Tracy with criminally negligent homicide, and, after a five-day bench trial in Family Court, she was adjudicated delinquent. Tracy appealed, arguing no reasonable factfinder could have found that she acted with criminal negligence or, even if she did, that it would be just to blame her for Alcee’s death given how unforeseeable it was that her attack would cause a 16-year-old to die from cardiac arrest. The Delaware Supreme Court agreed: a defendant cannot be held responsible for criminally negligent homicide unless there was a risk of death of such a nature and degree that her failure to see it was a gross deviation from what a reasonable person would have understood, and no reasonable factfinder could conclude that Tracy’s attack - which inflicted only minor physical injuries - posed a risk of death so great that Tracy was grossly deviant for not recognizing it. View "Cannon v. Delaware" on Justia Law

The Supreme Court reversed the decision of the court of appeals granting a writ of habeas corpus to Appellee and ordering his immediate discharge from the Ross Correctional Institution. In his petition, Appellee, who was seventeen years old at the time of the offense for which he was convicted, argued that the general division of the common pleas court lacked jurisdiction to try him as an adult because the juvenile court had failed to meet the requirements of Ohio Rev. Code 2152.12(G) before transferring his case. Specifically, Appellee argued that the failure to notify his legal custodian, his grandmother, of the transfer hearing was a violation of the statute, and therefore, the common pleas court lacked jurisdiction over the matter. The court of appeals agreed. The Supreme Court reversed, holding that the juvenile court satisfied the statutory requirements by serving notice on Appellee’s biological mother. View "Turner v. Hooks" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law

B.F. and C.W. lived in Calaveras County with a blended family that included six children, ranging from one to 15 years of age. Most of the family attended a Little League baseball game on April 27, 2013, leaving the house at approximately 7:00 a.m. Appellant I.F. then age 12, and his sister L.F., age 8, were home alone on that morning; during the course of the morning, someone entered L.F.’s bedroom and stabbed her to death. Later that day, and in the days that followed, I.F. made a series of inconsistent and cumulatively incriminating statements to police. A petition was filed under Welfare and Institutions Code section 602 alleging that I.F. committed murder and personally used a knife in the commission of the offense. Following a contested jurisdictional hearing, the juvenile court sustained the petition and found true the allegation that I.F. personally used a knife in the commission of the crime. I.F. appealed, arguing the juvenile court erroneously admitted his pre-arrest statements in violation of Miranda v. Arizona, 384 U.S. 436 (1966). After review, the Court of Appeal agreed that two of four challenged statements were inadmissible. Because the Miranda error was not harmless beyond a reasonable doubt under Chapman v. California, 386 U.S. 18 (1967), the Court reversed and remanded for further proceedings. View "In re I.F." on Justia Law