Justia Juvenile Law Opinion Summaries

In 1987, Defendant murdered his twelve-year-old sister. Defendant was fourteen years old at the time of the murder. Defendant was convicted of first degree murder and sentenced to life imprisonment. In 2013, Defendant filed a motion for postconviction relief, arguing that his sentence was cruel and unusual punishment in light of the U.S. Supreme Court decision in Miller v. Alabama. The district court vacated Defendant’s life sentence, finding that the sentence was within the parameters of the holding in Miller, that the rule in Miller applies retroactively, and that Defendant was therefore entitled to postconviction relief. The Supreme Court affirmed, holding that because the relevant sentencing scheme mandated life imprisonment without the possibility for parole, the district court was bound by Miller. Remanded for resentencing. View "State v. Thieszen" on Justia Law

Sandrino T. and Remus M. were each charged in the juvenile court with six counts of ATM “skimming.” In each case, the State moved to transfer to county court. The juvenile court granted the motions. Both Sandrino and Remus appealed. The Supreme Court consolidated the cases on appeal for disposition. The Court then dismissed each appeal for lack of jurisdiction, holding that the orders transferring the cases from juvenile court to county court were not final and appealable because the transfer of the cases from juvenile court to criminal court did not affect the substantial rights of Sandrino and Remus. View "In re Sandrino T." on Justia Law

Defendant pleaded guilty to two counts of armed sexual battery, armed burglary, and armed robbery. Defendant was fifteen years old at the time he committed the offenses. The trial court sentenced Defendant to two life sentences and two concurrent twenty-five-year terms. After Graham v. Florida was decided, the trial court resentenced Defendant to concurrent sentences of forty-five years. On appeal, the First District Court of Appeal concluded that Defendant was not entitled to resentencing under Henry v. State, which applied the new sentence review statute to a Graham-eligible defendant, because Defendant’s forty-five-year term of imprisonment did not constitute a de facto life sentence in violation of Graham. However, the district court certified a question to the Supreme Court regarding the need for clarity on a category of Graham cases. The Supreme Court disapproved the court of appeal’s decision affirming Defendant’s resentencing, holding that a defendant whose initial sentence for a nonhomicide crime violated Graham and who was resentenced to concurrent forty-five year terms was entitled to new resentencing under the framework established in chapter 2014-220, Laws of Florida. View "Kelsey v. State" on Justia Law

While J.S. was a dependent of the juvenile court, a delinquency petition was filed alleging that she committed vandalism and used force and violence against another minor. The juvenile court declared her a "dual status" child, making her both a dependent and a ward of the court. On appeal, J.S. argued that: (1) the juvenile court erred by failing to dismiss the delinquency petition and declaring her a dual status youth; (2) the court erred by detaining her in juvenile hall pending placement in a residential treatment facility; and (3) she was prejudiced by being declared a ward. The Court of Appeal rejected J.S.'s arguments and affirmed the judgment. View "In re J.S." on Justia Law

The State filed a petition in juvenile court alleging that sixteen-year-old Tyrone K. committed four counts of theft by receiving stolen property and one count of operating a motor vehicle to avoid arrest. The prosecutor moved to transfer the proceedings to criminal court. The juvenile court granted the motion to transfer after conducting an evidentiary hearing. Tyrone appealed, arguing that there was insufficient evidence for the juvenile court to transfer his case to criminal court. The Supreme Court dismissed the appeal, holding that the transfer order from which Tyrone appealed was not a final order. View "In re Interest of Tyrone K." on Justia Law

A grand jury indicted Montano, for 29 counts of first-degree murder, arising out of the 2013 shooting death of Solano, and 4 counts of attempted murder and 1 count of aggravated battery, arising out of the shooting of Maza. Montano was 15 years old at the time of the offenses. The charges were brought in criminal court, under section 5-130 of the Juvenile Court Act as then in effect. While the charges were pending, a statutory amendment raised the age for automatic adult prosecution for the enumerated offenses from 15 to 16. The prosecution objected to a transfer, arguing that because the implementation of the amendment was delayed until January 1, 2016, it was presumed to have a prospective effect. The court transferred the cause to juvenile court, reasoning that, because the legislature had not indicated the temporal reach of the amendment, the temporal reach was determined by section 4 of the Statute on Statutes. The court concluded that the juvenile transfer statute was procedural and would apply retroactively. The Illinois Supreme Court rejected the state’s petition for mandamus. The amendment was retroactive under the Statute on Statutes and belongs in juvenile court, unless it is transferred to criminal court pursuant to a discretionary transfer hearing. View "Alvarez v. Howard" on Justia Law

In February 2014, Jason Dakota Baxter (who then was sixteen years old) was arrested and charged with aggravated sexual battery. Baxter was detained pending indictment and trial. About a month after his arrest, Baxter executed a written waiver of his entitlement to have his case presented to the grand jury within 180 days, and Baxter and the State filed the waiver with the superior court. In October 2014, however, Baxter filed a motion to transfer his case to juvenile court, asserting that his case had not been timely presented to the grand jury as required by OCGA 17-7-50.1 and that his waiver was ineffective. The superior court granted the motion, and the State appealed. The Court of Appeals affirmed, finding that presentation to the grand jury within 180 days of detention was an absolute requirement (unless the time was extended for good cause), that such presentation was essential to the jurisdiction of the superior court, and that parties could not by agreement, consent, or waiver confer jurisdiction upon a court that otherwise was without it. The Supreme Court reversed, finding that the Court of Appeals misunderstood OCGA 17-7-50.1 when it concluded that the statute did not permit a detained child to waive presentation within 180 days of the date of detention. For that reason, the Court of Appeals erred when it affirmed the transfer from the superior court to the juvenile court. Accordingly, the Supreme Court reversed the judgment of the Court of Appeals. View "Georgia v. Baxter" on Justia Law

In 2013 while he was in custody, investigators questioned a then- 18-year-old Tyler Estrada abut a Gwinnett County homicide. Estrada had been in custody in DeKalb County. At an evidentiary hearing, audio recordings of Estrada’s custodial statement were placed into evidence, the trial court determined that though Estrada invoked his right to counsel, he never waived his Miranda rights either in writing or verbally. Accordingly, the trial court granted Estrada’s motion to suppress the statement. The State appealed. Finding no reversible error to that suppression order, the Supreme Court affirmed. View "Georgia v. Estrada" on Justia Law

Calvin S. was declared a ward of the court under Welfare and Institutions Code section 602 and committed to the DJF for a maximum term of 15 years four months after he committed assault with a firearm and assault with intent to commit a sexual offense. The court concluded that the juvenile court abused its discretion in committing Calvin to the DJF rather than letting him remain in juvenile hall. The court also concluded that the juvenile court should have stayed the term imposed for assault with intent to commit a sexual offense under Penal Code section 654. Accordingly, the court reversed the commitment order and remanded for a new disposition hearing. The juvenile court is directed to stay execution of any term of confinement imposed on the sustained allegation of assault with intent to commit a sexual offense. View "In re Calvin S." on Justia Law

Petitioner was sentenced to life imprisonment without parole for a nonhomicide offense he committed at the age of sixteen. After Graham v. Florida was decided, petitioner sought postconviction relief but the state courts denied it. The court concluded that petitioner's state court adjudication constituted an unreasonable application of Graham where Virginia courts unreasonably ignored the plain language of the procedures governing review of petitions for geriatric release, which authorize the State Parole Board to deny geriatric release for any reason, without considering a juvenile offender’s maturity and rehabilitation. In light of the lack of governing standards, the court concluded that it was objectively unreasonable for the state courts to conclude that geriatric release affords petitioner with the “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” Graham demands. Accordingly, the court affirmed the district court's grant of habeas relief and remanded so that petitioner can be resentenced in accordance with Graham and the Eighth Amendment. View "LeBlanc v. Mathena" on Justia Law