Justia Juvenile Law Opinion Summaries

The case involves a juvenile, Jose R., who was declared a ward of the court and committed to a secure youth treatment facility (SYTF) for a baseline term of three years with a maximum term of six years. This followed his admission, as part of a plea deal, that he had committed an assault with a semiautomatic firearm. The case arose from a shooting incident in which Jose and an adult man fired multiple gunshots, resulting in a victim's death. Initially, Jose was charged with first-degree murder, but the charge was later amended to assault with a semiautomatic firearm, which Jose admitted to.The Superior Court of Los Angeles County denied Jose's motion to apply his precommitment custody credits to his baseline term, instead applying the 395 days of precommitment custody credits against the maximum term. Jose appealed this decision, arguing that the court erred in applying his precommitment custody credits to his maximum term instead of his baseline term.The Court of Appeal of the State of California Second Appellate District Division Seven affirmed the lower court's decision. The appellate court found that the lower court did not err in applying Jose's precommitment custody credits to the maximum term of confinement. The court based its decision on the clear statutory language in section 875, subdivision (c)(1)(C), which states that precommitment custody credits must be applied against the maximum term of confinement. The court also rejected Jose's argument that the legislative scheme violated his right to equal protection of the laws. The court concluded that the legislative amendments did not violate equal protection principles, even if they resulted in less favorable treatment of precommitment credits. View "In re Jose R." on Justia Law

The case revolves around Audrey Mae Lessner, who was convicted of felony child abuse under Wyo. Stat. Ann. § 6-2-503(b)(i) (2023) after a bench trial. The charges stemmed from an incident where Lessner, while babysitting an 11-year-old child identified as FF, spanked the child eleven times with a belt as punishment for lying. The spanking resulted in significant bruising on the child's thigh. Lessner appealed her conviction, arguing that the district court abused its discretion by denying her motion to continue the trial and that the State failed to present sufficient evidence to prove that she did not engage in reasonable corporal punishment.Prior to the trial in the District Court of Sweetwater County, Lessner had sought to represent herself, a request that the court granted after advising her of the risks. She later filed a motion for an extension of time, claiming that the prosecution was not assisting her in obtaining information for a subpoena. However, she later informed the court that she no longer needed an extension and was ready for trial. On the first day of the bench trial, Lessner filed a motion for an emergency hearing, asserting that she was not ready to proceed because the State was denying some discovery. The court denied her motion and proceeded with the trial.The Supreme Court of Wyoming affirmed the lower court's decision. It found that the district court did not abuse its discretion in denying Lessner's motion to continue the trial. The court also found that the State presented sufficient evidence to demonstrate that the physical injury inflicted on the child was not the result of reasonable corporal punishment. The court noted that Lessner's actions, including her decision to use a belt to avoid injuring her hand and her refusal to stop spanking the child other than to rest her arm, did not represent a method of correction but rather an adult who had lost control of her own responses. View "Lessner v. The State of Wyoming" on Justia Law

James Massey was charged with gross sexual imposition, a class AA felony, and child abuse, a class C felony. The charges stemmed from an incident involving a minor, identified as T.T. During the trial, the State presented testimonies from T.T., law enforcement, medical staff, and a psychologist. Massey, in his defense, testified on his own behalf. The jury found Massey guilty of both charges.The case was first heard in the District Court of Cass County, East Central Judicial District. At the close of the State's case, Massey moved for a judgment of acquittal under N.D.R.Crim.P. 29, which the court denied. The jury found Massey guilty of both charges, and he subsequently appealed the convictions.The case was then reviewed by the Supreme Court of North Dakota. Massey argued that the jury instruction for gross sexual imposition was improper and that the State's closing arguments constituted prosecutorial misconduct. The Supreme Court affirmed the lower court's decision. The court found no error in the use of "willfully" as the required mens rea in the jury instructions. Although the court acknowledged that the State made an improper "golden rule" argument during closing arguments, it concluded that Massey failed to demonstrate how he was prejudiced by these comments. The court affirmed the judgment of conviction. View "State v. Massey" on Justia Law

In 2013, a minor identified as A.M. was tried as an adult and convicted for first-degree murder of a rival gang member, which he committed at the age of 14. He was sentenced to 26 years to life in prison. In 2021, the superior court conditionally reversed the judgment and ordered a transfer hearing under Proposition 57, which prohibits trying a minor as an adult without a judicial determination of their fitness for juvenile court. The juvenile court conducted the hearing, granted the district attorney’s motion to transfer A.M.’s case to criminal court, and reinstated the judgment.A.M. appealed, arguing that his case should not have been transferred because he was 14 years old when he committed his crime. He also contended that Assembly Bill 333, which amended various provisions of Penal section 186.22, required striking the gang-murder special circumstance. The Court of Appeal of the State of California Second Appellate District agreed with both of A.M.’s contentions.The court held that Senate Bill 1391, which amended Proposition 57 to prohibit the transfer of 14- and 15-year-olds to adult criminal court, applied to A.M.'s case. The court reasoned that when the superior court conditionally reversed A.M.'s conviction and sentence, his case became nonfinal, and thus, Senate Bill 1391 applied. The court also held that Assembly Bill 333 applied retroactively to A.M.'s case, requiring the vacating of the jury's gang-murder special circumstance finding. The court reversed the order granting the district attorney’s motion to transfer A.M.’s case to criminal court, vacated the true finding on the gang-murder special circumstance, and struck the requirement for A.M. to register as a gang offender. The case was remanded to the juvenile court for further proceedings. View "In re A.M." on Justia Law

The case revolves around a defendant who was convicted for enticement of a child. The defendant had approached a ten-year-old girl, A.W., while she was walking her dog. He drove into the opposing lane of traffic to pull his truck up beside her, asked her personal questions, and made inappropriate comments. Based on these events and evidence of the defendant’s previous behavior with a five-year-old girl in Louisiana, a jury convicted the defendant of enticement of a child.The defendant appealed his conviction, arguing that the evidence was insufficient to prove the offense of enticement. The court of appeals agreed with the defendant's argument, vacating his conviction on the ground that the evidence was insufficient to prove that the defendant had attempted to invite or persuade A.W. to enter his truck, or that he intended to commit unlawful sexual contact.The Supreme Court of the State of Colorado disagreed with the court of appeals' interpretation of the term "attempt" in the child enticement statute. The Supreme Court held that the term "attempt" in the statute should be interpreted according to its plain meaning, not as referring to the inchoate crime of "attempt" defined in another statute. The Supreme Court found that the defendant's words and actions, taken together and viewed in the light most favorable to the prosecution, constituted sufficient evidence for a reasonable person to conclude that the defendant attempted to invite or persuade the victim to enter his vehicle with the intent to commit unlawful sexual contact upon her. Therefore, the Supreme Court reversed the court of appeals’ decision vacating the defendant’s conviction and remanded the case to the court of appeals to address his remaining appellate arguments. View "People v. Johnson" on Justia Law

The case involves a juvenile, Jeovani H., who was placed on probation and ordered to pay restitution as a term and condition of his probation. Jeovani was charged with an act that would constitute the felony of first-degree assault, which was later amended to a misdemeanor of attempted third-degree assault. The incident involved Jeovani shoving another youth, causing the youth to fall and fracture his arm. As part of a plea agreement, Jeovani admitted to the amended petition and agreed that the amount of restitution owed to his victim for medical expenses was $2,553.05. However, he disputed his ability to pay that amount.The Hall County Court, sitting as a juvenile court, accepted Jeovani’s admission to the amended petition and ordered a predisposition investigation. At the disposition and restitution hearing, Jeovani’s mother testified about the family's financial situation and work schedules, arguing that Jeovani did not have the ability to pay the restitution amount. The State called Jeovani and a juvenile probation officer as witnesses, who testified about Jeovani's ability to work and earn money to pay the restitution.The Nebraska Supreme Court affirmed the juvenile court's decision. The court found that Jeovani had the ability to pay the restitution within the 12-month period of his probationary term. The court also rejected Jeovani’s claim that he was not allowed an opportunity to present or cross-examine witnesses on the issue of restitution. The court concluded that the restitution order was consistent with Jeovani’s reformation and rehabilitation and was supported by the record. View "In re Interest of Jeovani H." on Justia Law

The case revolves around Joshua Reber, who was convicted for sexually abusing a young child. The child, K.W., testified in detail about the abuse, which began when she was eight years old. Reber admitted to taking K.W. into the woods alone at night without informing anyone but denied any sexual abuse. During his testimony, Reber also discussed his normal sexual relationships with adult women. The prosecutor cross-examined Reber about his text messages with a woman named Danielle, which indicated sexual encounters. Reber did not object to these questions.The jury found Reber guilty, and he was sentenced to two consecutive terms of 300 to 420 months in prison. Reber appealed, arguing that the admission of his cross-examination testimony and the prosecutor's statements during closing arguments were errors. The Court of Appeals reversed Reber’s convictions, holding that the introduction of the challenged evidence on cross-examination amounted to plain error and that the prosecutor’s statements during closing argument were so grossly improper that the trial court should have intervened on its own initiative.The Supreme Court of North Carolina disagreed with the Court of Appeals' decision. The court held that the admission of the cross-examination testimony was not plain error and that the prosecutor's statements during closing arguments were not so grossly improper that the trial court should have intervened. The court reversed the decision of the Court of Appeals and remanded the case for consideration of Reber’s remaining arguments. View "State v. Reber" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law