Justia Juvenile Law Opinion Summaries

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

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