Justia Juvenile Law Opinion Summaries

The Court of Appeals affirmed the order of the Appellate Division ruling that Teri W.’s ten-year probation sentence was legal. Teri W. pleaded guilty to one count of sexual abuse in the first degree, a class D felony sex offense, for an offense she committed when she was seventeen years old. Supreme Court deemed her conviction vacated and replaced by a youthful offender finding and sentenced her to ten years’ probation. On appeal, Teri W. argued that her probation sentence illegally exceeded the five-year maximum for undesignated class E felonies. The Court of Appeals affirmed, holding that the sentence was lawful. View "People v. Teri W." on Justia Law

Sixteen-year-old defendant Adrian Vela and one of his fellow gang members confronted two suspected rival gang members. Vela’s accomplice pulled out a gun and shot the two victims, killing one of them. Charged as an adult, a jury found Vela guilty of murder, attempted murder, and found true the related firearm and gang allegations. Vela made several interrelated claims of instructional error concerning accomplice liability, and Vela raised two constitutional challenges to his 72 years to life sentence. In the unpublished parts of its opinion, the Court of Appeal found no reversible error with respect to the trial court’s jury instructions. Furthermore, the Court found Vela’s sentence did not violate either the equal protection clause or the Eighth Amendment. In the published portion of its opinion, the Court of Appeal conditionally reversed the judgment because of Proposition 57. “Vela is retroactively entitled to a transfer hearing because his case is not yet final on appeal. If, after conducting the hearing, the juvenile court judge determines that Vela’s case should be transferred to a court of criminal jurisdiction, then his convictions will be reinstated. . . . But if the juvenile court determines that Vela is amenable to rehabilitation, and should remain within the juvenile justice system, then his convictions will be deemed juvenile adjudications. The juvenile court is then to impose an appropriate disposition within its discretion under juvenile court law.” View "California v. Vela" on Justia Law

Sixteen-year-old defendant Adrian Vela and one of his fellow gang members confronted two suspected rival gang members. Vela’s accomplice pulled out a gun and shot the two victims, killing one of them. Charged as an adult, a jury found Vela guilty of murder, attempted murder, and found true the related firearm and gang allegations. Vela made several interrelated claims of instructional error concerning accomplice liability, and Vela raised two constitutional challenges to his 72 years to life sentence. In the unpublished parts of its opinion, the Court of Appeal found no reversible error with respect to the trial court’s jury instructions. Furthermore, the Court found Vela’s sentence did not violate either the equal protection clause or the Eighth Amendment. In the published portion of its opinion, the Court of Appeal conditionally reversed the judgment because of Proposition 57. “Vela is retroactively entitled to a transfer hearing because his case is not yet final on appeal. If, after conducting the hearing, the juvenile court judge determines that Vela’s case should be transferred to a court of criminal jurisdiction, then his convictions will be reinstated. . . . But if the juvenile court determines that Vela is amenable to rehabilitation, and should remain within the juvenile justice system, then his convictions will be deemed juvenile adjudications. The juvenile court is then to impose an appropriate disposition within its discretion under juvenile court law.” View "California v. Vela" on Justia Law

The Supreme Court affirmed the order of the separate juvenile court transferring Steven S.’s case to county court, holding that there was no abuse of discretion in the transfer.The State charged Steven, a juvenile, with escape and simultaneously filed a motion to transfer Steven’s case from juvenile court to county court. The juvenile court concluded that the State had proved by a preponderance of the evidence that the matter should be transferred to county court. The Supreme Court affirmed, holding that, upon the Court’s de novo review of the record, the juvenile court did not abuse its discretion in ordering that Steven’s case be transferred to county court. View "In re Interest of Steven S." on Justia Law

The Supreme Court affirmed Defendant’s convictions of two counts of first degree murder and two counts of use of a deadly weapon to commit a felony, holding that Defendant’s assignments of error were without merit.On appeal, Defendant argued that the district court erred by not admitting photographs he claimed supported his defense that another individual committed the murders and that his collective sentence of ninety to 140 years’ imprisonment was the functional equivalent of a sentence of life imprisonment. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in excluding the photographs by reasoning that the small amount of relevance was outweighed by Neb. Evid. R. 403; and (2) Defendant, who was a juvenile at the time the crimes were committed, received the protections required by Miller v. Alabama, 567 U.S. 460 (2012). View "State v. Trotter" on Justia Law

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