Justia Juvenile Law Opinion Summaries

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

M.T., a 16-year-old juvenile, was charged with simple assault and willful concealment. His parents expressed that they did not feel safe with him at home and requested residential treatment. M.T. was placed in shelter care but was removed due to dangerous behavior, including physical altercations and property damage. The shelter exercised its right to terminate treatment, leading to M.T.'s placement at the Sununu Youth Services Center (SYSC).The Circuit Court held an adjudicatory hearing where M.T. pled true to the charges. The court scheduled a dispositional hearing and, in the interim, heard arguments regarding M.T.'s placement. The juvenile probation and parole officer (JPPO) testified that no alternative placements were available. The court ordered M.T. to be detained at SYSC, citing the lack of less restrictive options and the need for M.T.'s safety and supervision.At the dispositional hearing, the State recommended that M.T. remain at SYSC due to his behavior and the lack of alternative placements. M.T. requested to return to his parents, but the court found this unsuitable. The court committed M.T. to SYSC for the remainder of his minority, emphasizing the need for intensive care and supervision and the unavailability of other options. The court also ordered the Department of Health and Human Services (DHHS) to continue searching for less restrictive placements, including out-of-state options.The New Hampshire Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the trial court sustainably exercised its discretion in considering the lack of available placements and committing M.T. to SYSC. The court also found that M.T. waived his argument regarding the right to counsel during the Comprehensive Assessment for Treatment (CAT) interview. View "In re M.T." on Justia Law

T.B., a juvenile, was adjudged delinquent by the Superior Court of the District of Columbia for carrying a pistol without a license and possessing unregistered ammunition. The case arose from two Instagram live videos observed by Officer Moore of the Metropolitan Police Department. In the first video, T.B. was seen displaying a black Glock-style handgun. In the second video, T.B. was seen with a light-colored object in his waistband, which officers believed to be a firearm. When officers arrived at the scene, they found a tan-gold-colored pistol on the ground near where T.B. had been standing.The Superior Court incorporated Officer Moore’s testimony from a suppression hearing into the trial. Officer Moore testified about the events leading to T.B.'s arrest and the officers' observations from the Instagram videos. Officer Laielli also testified, describing T.B.'s behavior in the second video as characteristic of an armed gunman. The court found the evidence sufficient to prove beyond a reasonable doubt that T.B. possessed the tan-gold-colored pistol and committed him to the Department of Youth Rehabilitation Services for up to one year.On appeal, T.B. argued that the evidence was insufficient to support the court’s findings and that the trial court erred in admitting the officers’ testimony. The District of Columbia Court of Appeals reviewed the case and found that the evidence, including the Instagram videos and the officers’ observations, was sufficient to support the trial court’s findings. The appellate court also concluded that any error in admitting the officers’ testimony was harmless, as the trial court’s findings were based on its own viewing of the video evidence. The Court of Appeals affirmed the judgment of delinquency. View "In re T.B." on Justia Law

Hunter de la Garza, a former employee of the Northwest Arkansas Children’s Shelter, was convicted of raping a ten-year-old female resident of the Shelter. The incident occurred during an outing to a mall, where de la Garza followed the victim into a restroom, forcibly undressed her, and raped her. The victim disclosed the rape to her brother and a friend, and later to a professional interviewer. The Shelter’s staff observed behavioral changes in the victim consistent with sexual abuse. De la Garza was interviewed by police and provided inconsistent accounts of the events.The Benton County Circuit Court denied de la Garza’s motion for a directed verdict, finding sufficient evidence to support the conviction. The court also allowed testimony from another young female resident of the Shelter, who described similar abuse by de la Garza, under the “pedophile exception” to Rule 404(b) of the Arkansas Rules of Evidence. The jury found de la Garza guilty and sentenced him to life in prison. De la Garza’s motion for a new trial was denied.The Arkansas Supreme Court reviewed the case and affirmed the conviction. The court held that the victim’s testimony, along with corroborating evidence, constituted substantial evidence to support the conviction. The court also found no abuse of discretion in admitting the testimony of the other young resident under the pedophile exception. Additionally, the court determined that de la Garza’s arguments regarding prosecutorial comments were not preserved for appeal, as he failed to contemporaneously object or request further relief during the trial. The court conducted a Rule 4-3(a) review and found no prejudicial error. View "HUNTER DE LA GARZA v. STATE OF ARKANSAS" on Justia Law

Defendant Benny Townes was convicted of multiple sexual offenses against his biological daughters, Jane Doe 1 and Jane Doe 2. Jane Doe 1, who was 16 years old, was raped and impregnated by the defendant. Jane Doe 2, who was 13 and 14 years old at the time, was raped, sodomized, and subjected to lewd acts by the defendant. The defendant admitted to having sexual intercourse with Jane Doe 1 but argued that it was consensual and not against her will.The Superior Court of Riverside County found the defendant guilty on all counts, including forcible rape, incest, lewd acts with a minor, and sodomy. The court sentenced him to 150 years to life in prison. The defendant appealed, contending that there was insufficient evidence to support the finding that he raped Jane Doe 1 by means of force or duress, and therefore, his convictions on counts 1 and 2 should be reversed. He also argued that the multiple victim enhancement allegations should be reversed if counts 1 and 2 were overturned.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case and affirmed the judgment. The court held that substantial evidence supported the finding of duress, which can be purely psychological. The defendant had instilled in Jane Doe 1 the belief that he was the son of God and that disobeying him would result in divine retribution. This psychological coercion was sufficient to constitute duress under Penal Code section 261, subdivisions (a)(2) and (b)(1). The court concluded that the threat of divine retribution, as taught by the defendant, was enough to uphold the convictions for forcible rape. View "People v. Townes" on Justia Law

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

A juvenile was involved in an altercation at the Barnstable District and Juvenile Court, where he was charged with disorderly conduct and assault and battery. The incident was captured on video, showing the juvenile and the victim engaging in a physical fight. The juvenile had a prior continuance without a finding (CWOF) after admitting to sufficient facts for an assault and battery charge.The Juvenile Court adjudicated the juvenile delinquent on both charges and sentenced him to one year of probation for each. The juvenile appealed, arguing that the court lacked jurisdiction over the disorderly conduct charge because a CWOF after an admission to sufficient facts should not count as a prior offense under G. L. c. 119, § 52. The Appeals Court did not review the case as it was transferred to the Supreme Judicial Court.The Supreme Judicial Court held that a CWOF entered after an admission to sufficient facts is sufficient to establish a first offense under § 52. Therefore, the Juvenile Court had jurisdiction over the disorderly conduct charge. The court also found that the evidence was sufficient to support the juvenile's adjudications of delinquency for both disorderly conduct and assault and battery. The court affirmed the adjudications, concluding that the juvenile did not act in self-defense and that his actions met the criteria for disorderly conduct. View "Commonwealth v. Fayad F." on Justia Law

In January 2008, Ignacio Ruiz, Jr., participated in an attack on rival gang members, resulting in one death. Ruiz, who was 16 at the time, was found guilty of first-degree murder, attempted murder, and street terrorism, with several gang and firearm enhancements. In August 2010, he was sentenced to life in prison without the possibility of parole for the murder charge, a consecutive life term with the possibility of parole for attempted murder, and a consecutive 25-year term for the firearm enhancement. Ruiz was resentenced in 2016, receiving nearly the same sentence.Ruiz filed a petition for resentencing in March 2023 under section 1170, subdivision (d), which allows individuals sentenced to life without parole for crimes committed as minors to petition for resentencing after 15 years of incarceration. The trial court denied the petition, calculating Ruiz's incarceration period from his sentencing date in August 2010, and found he had not been incarcerated for 15 years.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court agreed with Ruiz's argument that his incarceration period began in January 2008 when he was taken into custody for the charges, not from his sentencing date. The court found that Ruiz had been incarcerated for over 15 years by the time he filed the petition. The court reversed the trial court's order and remanded the case for reconsideration of the petition, clarifying that the period of incarceration for purposes of section 1170, subdivision (d)(1)(A), begins when the individual is placed in custody, not when they are sentenced. View "People v. Ruiz" on Justia Law

In 2018 and 2019, the appellant, a minor, committed a series of crimes, including seven street robberies, two burglaries, an attempted robbery resulting in murder, and the sexual assault of a 14-year-old girl. The appellant was 16 and 17 years old at the time of these offenses. The People filed an 18-count petition against the appellant, including charges of murder, robbery, burglary, and sexual assault, and sought to transfer the appellant to adult criminal court.The juvenile court held a transfer hearing and considered extensive evidence, including the appellant's family and social history, conduct in custody, and expert testimony. The court found that the appellant was not amenable to rehabilitation within the juvenile system's timeframe and ordered the transfer to adult criminal court. The court's decision was based on the severity and sophistication of the crimes, the appellant's delinquent history, and the lack of sufficient time for rehabilitation before the juvenile court's jurisdiction expired.The appellant appealed the transfer order, arguing that the juvenile court abused its discretion and that the evidence did not support the transfer. The California Court of Appeal, Second Appellate District, reviewed the case and upheld the juvenile court's decision. The appellate court found that the juvenile court had properly considered the statutory criteria for transfer and that substantial evidence supported the finding that the appellant was not amenable to rehabilitation within the juvenile system. The order transferring the appellant to adult criminal court was affirmed. View "People v. J.S." on Justia Law

The defendant, a 16-year-old student, was charged with assault with intent to commit great bodily harm less than murder (AWIGBH) under an aiding and abetting theory. The incident involved two other students, TI and CB, who attacked the victim by hitting and kicking him. The defendant did not participate in the physical attack but recorded the incident on his cell phone and shared the video with other students. The prosecution argued that the defendant's recording of the attack encouraged the assailants. Instead of filing a juvenile petition, the prosecution sought to try the defendant as an adult under the automatic waiver statute, arguing that the shoes worn by the assailants were used as dangerous weapons.The 53rd District Court found probable cause to believe that the defendant had aided and abetted the assault and bound him over to the criminal division of the circuit court. The circuit court denied the defendant's motion to quash the bindover and dismiss the charges, concluding that a shoe could be used as a dangerous weapon. The Court of Appeals affirmed the circuit court's decision, with a dissenting opinion arguing that the shoes did not constitute dangerous weapons and that the defendant was not armed with a dangerous weapon.The Michigan Supreme Court reviewed the case and held that for the criminal division of the circuit court to have jurisdiction under the automatic waiver statute, the juvenile defendant must be armed with a dangerous weapon. The Court found no evidence that the defendant was armed with a dangerous weapon during the assault. Consequently, the statutory requirements for automatic waiver were not met, and the criminal division of the circuit court did not have jurisdiction over the defendant. The Court reversed the Court of Appeals' judgment in part, vacated it in part, and remanded the case to the circuit court to grant the defendant's motion to quash the bindover and transfer the case to the family division of the circuit court. View "People Of Michigan v. Oslund" on Justia Law