Justia Juvenile Law Opinion Summaries

The defendants in these appeals committed very serious, violent crimes when they were juveniles. One was serving a sentence of 110 years imprisonment and would not be eligible for parole until he spent 55 years in jail. At that time, he would be about 72 years old. The second was serving a 75-year term and was ineligible for parole until he served 68 years and 3 months in jail. He would then be 85 years old. The United States Supreme Court recognized the mitigating qualities of youth and directed that judges in those cases consider a number of factors at sentencing, including immaturity and failure to appreciate risks and consequences; family and home environment; family and peer pressures; an inability to deal with police officers or prosecutors or the juvenile s own attorney; and the possibility of rehabilitation. The New Jersey Court found the same concerns applied to sentences that were the practical equivalent of life without parole, like the ones in these appeals. "The proper focus belongs on the amount of real time a juvenile will spend in jail and not on the formal label attached to his sentence. To satisfy the Eighth Amendment and Article I, Paragraph 12 of the State Constitution, which both prohibit cruel and unusual punishment, we direct that defendants be resentenced and that the 'Miller' factors be addressed at that time. [. . .] In short, judges should exercise a heightened level of care before they impose multiple consecutive sentences on juveniles which would result in lengthy jail terms." Both cases were remanded for resentencing. View "New Jersey v. Zuber" on Justia Law

In 2003, Murdock was convicted of first-degree murder and aggravated battery with a firearm. In connection with his post-conviction claim of ineffective assistance of counsel, a suppression hearing was held to determine whether Murdock's statements to the police were voluntary, given that Murdock was 16 years old and was without an attorney or other adult present. The Illinois Supreme Court affirmed denial of a motion to suppress. The federal district court denied habeas relief under 28 U.S.C. 2254, finding that the Illinois Supreme Court’s decision was not unreasonable. The Seventh Circuit affirmed: the court applied the correct test in a reasonable manner in finding that the totality of the circumstances indicated that Murdock gave his statements voluntarily. The court considered Murdock’s age, and that he did not have an attorney or other adult present, but found that he was able to understand and provide an adequate waiver of his rights. The court considered that Murdock was detained for approximately seven hours, but noted that the interview lasted only three hours and that Murdock was given the opportunity to eat and use the restroom. There was no evidence that the officers threatened him or otherwise created a coercive environment. The court found that Murdock did not appear to be under distress or frightened on a video recording. View "Murdock v. Dorethy" on Justia Law

In 2001, Appellant was convicted of first degree murder and use of a firearm during the commission of a felony. Appellant was sixteen years old when he committed the crimes leading to his convictions. Appellant was sentenced to life imprisonment on the murder conviction. In 2013, Appellant filed a motion for postconviction relief seeking resentencing on his murder conviction pursuant to Miller v. Alabama. The district court granted postconviction relief. After a resentencing hearing, Appellant was sentenced to ninety to ninety years’ imprisonment on the first degree murder conviction. Appellant appealed, arguing that the district court imposed an excessive sentence. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing a sentence within the statutory limits and supported by the record, and there was no merit to Appellant’s claim that his sentence was excessive. View "State v. Garza" on Justia Law

The two defendants in this case were juveniles when they fatally shot their victims. Defendants were each convicted of first degree murder. Defendants were sentenced to natural life imprisonment under Ariz. Rev. Stat. 13-703, meaning they were not eligible for release. After Miller v. Alabama was decided, each defendant filed a petition for post-conviction relief under Ariz. R. Crim. P. 32.1(g). In each case, the trial court summarily denied relief, concluding that the sentencing court had complied with Miller and that any constitutional infirmity in Arizona’s sentencing scheme had been resolved by 2014 statutory amendments. The Supreme Court vacated the opinion of the court of appeals, reversed the trial court’s dismissal of the petitions for post-conviction relief, and remanded for further proceedings, holding that Defendants were entitled to evidentiary hearings on their Rule 32.1(g) petitions because they made colorable claims for relief based on Miller. View "State v. Valencia" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated robbery, three counts of rape, and other offenses. Defendant was fifteen years old at the time he committed the crimes. The trial court sentenced Defendant to the maximum prison term for each count. The sentence totaled 141 years in prison. At issue before the Supreme Court in this appeal was whether, pursuant to Graham v. Florida, a term-of-years prison sentence that exceeds a defendant’s life expectancy violates the Eighth Amendment’s prohibition against cruel and unusual punishments when it is imposed on a juvenile nonhomicide offender. The Supreme Court answered this question in the affirmative and remanded the cause to the trial court for resentencing, holding (1) Graham’s categorical prohibition of sentences of life imprisonment without the possibility of parole for juveniles who commit nonhomicide crimes applies to juvenile nonhomicide offenders who are sentenced to term-of-years sentences that exceed their life expectancies; and (2) therefore, Defendant’s 112-year sentence violates the Eighth Amendment. View "State v. Moore" on Justia Law

A complaint was filed in the juvenile court alleging that Appellant engaged in conduct that would be considered aggravated robbery if committed by an adult. Appellant was sixteen years old at the time of the alleged offense. The State filed a motion to transfer Appellant to the general division of the common pleas court to be tried as an adult pursuant to Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b), which provide for mandatory transfer of juveniles to adult court in certain circumstances. After a hearing, the juvenile court automatically transferred the case. Appellant moved to dismiss the ensuring indictment charging him with two counts of aggravated robbery with accompanying firearm specifications and transfer his case back to juvenile court, arguing that mandatory transfer of juveniles is unconstitutional. The trial court overruled the motion. Appellant subsequently entered pleas of no contest to the two counts of aggravated robbery. The court of appeals affirmed. The Supreme Court reversed, holding that mandatory transfer of juveniles to adult court without providing for the protection of a discretionary determination by the juvenile court judge violates juveniles’ right to due process. View "State v. Aalim" on Justia Law

Defendant was charged by criminal information with sexual assault in the first degree and risk of injury to a child. Based on the seriousness of the offenses and the allegation that Defendant’s conduct occurred when he was fourteen years old, the case was automatically transferred from the juvenile docket to the regular criminal docket. After a jury trial, Defendant was convicted of two counts of sexual assault int he first degree and one count of risk of injury to a child. The Appellate Court vacated the convictions, concluding that the trial court erred by denying Defendant’s post trial motion to dismiss the information because the State had failed to prove beyond a reasonable doubt that the conduct underlying the convictions had occurred after Defendant’s fourteenth birthday. The Supreme Court affirmed, holding that the State did not establish, under any burden of proof, that Defendant was at least fourteen years old at the time he committed the offenses for which he was convicted. View "State v. Samuel M." on Justia Law

Defendant was convicted of murder. Defendant committed the crime when he was seventeen years old. In 1992, Defendant was sentenced to fifty years’ imprisonment without parole. In 2013, Defendant filed a motion to correct his allegedly illegal sentence, arguing that he was entitled to resentencing on the basis of recent changes to juvenile sentencing law. The trial court dismissed the motion for lack of jurisdiction. The Supreme Court affirmed, holding that court precedent does not require a trial court to consider any particular mitigating factors associated with a juvenile’s age before imposing a sentence that includes an opportunity for parole, and therefore, Defendant has not raised a colorable claim of invalidity that would require resentencing. View "State v. Boyd" on Justia Law

Defendant was two months short of his eighteenth birthday when he shot and killed Timothy Irving. After a jury trial, Defendant was convicted of eight felonies, including first degree murder. The trial court sentenced Defendant to life in prison for the first degree murder charge. Defendant appealed the trial court’s refusal to appoint a neuropsychologist at the Commonwealth’s expense to assist in the preparation of his presentence report and its decision to impose a life sentence. The court of appeals denied Defendant’s petition for appeal with regard to the denial of his motion for a neuropsychologist but granted his petition with regard to the sentence imposed. The court of appeals then concluded that the trial court did not err in sentencing Defendant because a sentence of life did not exceed the statutory maximum penalty for first-degree murder and that because Defendant was not facing a mandatory life sentence, Miller v. Alabama did not apply. The Supreme Court affirmed, holding (1) Defendant failed to show any abuse of discretion in the trial court’s decision that mandated review by the court of appeals; and (2) Miller has no application to the present case. View "Johnson v. Commonwealth" on Justia Law

A petition filed under Welfare and Institutions Code 602 alleged that E.G. committed four offenses. He pled no contest to battery causing serious bodily injury and grand theft; the remaining charges were dismissed. The offenses E.G. pled no contest to were “wobblers,” offenses (Penal Code 17(b)(3)) that “are chargeable or, in the discretion of the court, punishable as either a felony or a misdemeanor.” The petition alleged them as felonies. The juvenile court placed E.G. on probation and committed him to a youth facility for nine months. The court of appeal remanded, finding the juvenile court had not exercised its discretion to declare the offenses misdemeanors or felonies as required by statute. Months later, E.G. moved to have his offenses reduced to misdemeanors under section 17(b), stating that the juvenile court had declared the offenses to be felonies. The state did not dispute this statement, although no such declaration was made on remand. The juvenile court denied the motion, finding that section 17(b)(3) did not apply in juvenile proceedings. A bench officer subsequently stated he had declared the offenses to be felonies at disposition and did so again. The court then terminated E.G.’s wardship and probation. Holding that the “wobbler” provision applies in juvenile proceedings, the court of appeal remanded to allow the juvenile court to exercise its discretion. View "In re E.G." on Justia Law