Justia Juvenile Law Opinion Summaries

Defendant was convicted of murdering his mother and conspiracy to murder his stepfather. Defendant was sixteen years old at the time he committed the crimes and was sentenced to a term of life without the possibility of parole (LWOP). Defendant seeks resentencing in light of Miller v. Alabama. Miller held that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders. After the trial court reimposed the LWOP term, the Supreme Court issued Montgomery v. Louisiana, which held that Miller announced a substantive rule of law that had retroactive application in state collateral review proceedings. The court reversed and remanded for resentencing because the trial court exercised its discretion in resentencing defendant without the guidance provided by Montgomery. View "People v. Padilla" on Justia Law

Police responded to a domestic disturbance involving then 16-year-old A.L.-C., who was feuding with he mother and stepfather on the first floor of the family home. B.O., his sister, told an aunt who was in the house, that A.L.-C. had sexually assaulted her. B.O. repeated her allegations to the police. A.L.-C. was briefly detained, but then returned to his parents. The following day, A.L.-C. and his parents went to the police station for questioning about the alleged sexual assaults. A detective and Spanish interpreter advised the three of A.L.-C.'s "Miranda" rights, then the detective and interpreter stepped out of the room to allow the family to discuss whether A.L.-C. would waive his rights. A videorecorder captured their exchange. Initially, the tape showed the parents individually asking A.L.-C. whether he understood his rights. A.L.-C. replied that he was "always the liar, or the one lying" and told his mother he would rather keep quiet. Whether A.L.-C. meant this as a refusal to speak with his mother or with the police was unclear. Minutes later, the detective and interpreter re-enetered the room and A.L.-C. and his mother both signed the Miranda waiver form. A.L.-C. indicated he understood his rights and agreed to discuss his sister's allegations. A.L.-C.'s stepfather left the room before more questioning began, but his mother remained for its entirety. At issue was A.L.-C.'s statement to his mother outside of police presence. The trial court suppressed A.L.-C.'s incriminating statements, concluding that although his mother was present, she could not protect his right to remain silent because she did not share his interests. The State sought the Colorado Supreme Court's review. Finding that the plain language of section 19-2-511(1) C.R.S. (2016) required only that a parent be present during the advisement and interrogation, the Supreme Court reversed the suppression order. View "People in the Interest of A.L.-C." on Justia Law

Defendant was required to register as a sex offender in Michigan because he was adjudicated a juvenile delinquent for a sex offense. Defendant later moved to Kentucky, where he was charged with failing to register under the Kentucky Sex Offender Registration Act. Defendant entered a conditional guilty plea to the charge. The court of appeals affirmed on appeal, concluding that Defendant was required to register under the plain language of the Act. Defendant appealed, claiming that he was not required to register under the Act because he was a juvenile and was not “convicted” of any crime. The Supreme Court affirmed, holding (1) the statute requires registration in the state of Kentucky of any person who was required to register in another state upon that person’s relocation; and (2) because Defendant was required to register in Michigan, he was also required to register in Kentucky. View "Murphy v. Commonwealth" on Justia Law

In 2010, the circuit court adjudicated Minnis a delinquent minor for committing the offense of criminal sexual abuse (720 ILCS 5/12-15(b) and sentenced him to 12 months’ probation. The adjudication for criminal sexual abuse rendered him a “sex offender” pursuant to the Registration Act (730 ILCS 150/2(A)(5), (B)(1); the court ordered Minnis to register as a sex offender. On December 17, 2010, defendant reported to the Normal police department to register. He disclosed his two e-mail addresses and his Facebook account. Defendant’s May 2011 registration form listed the same Internet information. Defendant registered again in August 2014, including his two e-mail addresses, but omitting his Facebook account. On September 9, Normal police officers viewed defendant’s publicly accessible Facebook profile online; Minnis had changed his Facebook cover photo only one month before his August 2014 registration. The circuit court of McLean County dismissed a charge of failure to register, finding that the Internet disclosure provision was overbroad in violation of the First Amendment. The Illinois Supreme Court reversed and remanded for trial, treating the challenge as one to facial validity. The Internet disclosure provision survives intermediate scrutiny. It advances a substantial governmental interest without chilling more speech than necessary. View "People v. Minnis" on Justia Law

Defendant was charged with aggravated robbery, a Class 1 felony (720 ILCS 5/18-5). Before trial, the prosecution and defense agreed that the sentencing range would be 4-30 years. Defendant’s counsel stated that the state had tendered a “certified court docket from the ’04 JD case” indicating that defendant, as a juvenile, had been adjudicated delinquent on multiple counts of residential burglary, which would make defendant eligible for an extended-term sentence. Counsel also indicated that defendant denied having an adjudication for residential burglary. The court admonished defendant that he faced a sentencing range of 4-30 years. At trial, the evidence was limited to the aggravated robbery charge. No evidence regarding defendant’s prior juvenile adjudication was introduced. The jury found defendant guilty. A presentencing investigative report indicated that defendant, as a juvenile, had been adjudicated delinquent in 2005 of multiple offenses, including three counts of residential burglary. The appellate court and Illinois Supreme Court affirmed defendant’s extended-term sentence of 24 years’ imprisonment, rejecting arguments that the sentence violated Supreme Court rulings in Apprendi v. New Jersey (2000) and Shepard v. United States (2005). Defendant’s prior juvenile adjudication is the equivalent of a prior conviction under Apprendi and falls within Apprendi’s prior-conviction exception and an exception in section 111-3(c-5) of the Illinois Criminal Code. The state was not required to allege the fact of his juvenile adjudication in the indictment or prove its existence beyond a reasonable doubt. View "People v. Jones" on Justia Law

A jury found defendant Alden Morgan, committed armed robbery at age 17. Following return of the guilty verdict, the district court sentenced him to 99 years imprisonment at hard labor without benefit of parole, probation, or suspension of sentence. After being denied relief on direct review, defendant filed a motion to correct an illegal sentence in light of recent developments in Eighth Amendment jurisprudence pertaining to the sentencing of juveniles. The Louisiana Supreme Court granted the defendant’s writ application to determine whether the defendant’s 99-year sentence was an effective life sentence and was, therefore, illegal under the Supreme Court’s decision in "Graham v. Florida," (560 U.S. 48 (2010)). The Louisiana Court held that a 99-year sentence without parole was illegal because it did not provide the defendant “with a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Accordingly, the Court amended defendant’s sentence to delete the restriction on parole eligibility. View "State ex rel Moran v. Louisiana" on Justia Law

Defendant-appellant Javante Scott appealed after the trial court, at a resentencing hearing, imposed the same 120-years-to-life term as at his original sentencing. Defendant was a minor at the time he committed his crimes, but was tried as an adult and convicted of three counts of attempted murder with firearm enhancements. Defendant argued the sentence was cruel and unusual because it imposed a de facto life sentence on him as a juvenile offender. The State argued that a new statute, Penal Code section 3051,1 which guaranteed defendant a future parole eligibility hearing, rendered the sentence constitutional. After review, the Court of Appeals held that section 3051 complied with the central constitutional requirement that the State provide a juvenile offender with a meaningful opportunity to obtain release within his or her expected lifetime. For this reason, the Court affirmed but with directions that the trial court determined whether defendant was afforded an adequate opportunity to make a record that complied with the requirements set forth in "California v. Franklin" (63 Cal.4th 261 (2016)). View "California v. Scott" on Justia Law

Similar to "Colorado v. Johnson," (2016 CO 69 (2016)), at issue in this case were questions involving what a trial court could order when a juvenile seeks a reverse-transfer of her criminal case from trial court to juvenile court. Defendant Brooke Higgins was a juvenile respondent before a magistrate judge. The district attorney requested, and Higgins' then-defense-counsel agreed to, a state administered mental health assessment of Higgins. Because the parties agreed, the magistrate judge ordered the assessment. Later, in front of a trial court, the DA dismissed the juvenile charges against Higgins and charged her as an adult with two counts of conspiracy to commit murder. Higgins sought, and the trial court granted, a reverse-transfer hearing to determine whether she should remain in adult court. Before that hearing, Higgins, now represented by different counsel, filed a motion to suppress the mental health assessment and disqualify the trial court judge. The trial court denied both requests, holding that the parties stipulated to the assessment, and there was independent statutory authority for the magistrate judge to order the assessment. Higgins appealed, arguing the trial court lacked authority to order a juvenile-charged-as-an-adult to undergo a mental health assessment for a reverse-transfer hearing. The Supreme Court found that based on the facts of this case, Higgins' arguments, while loosely related to those in "Johnson," were hypothetical and premature. The Court therefore vacated the trial court's order and remanded the case for further proceedings. View "Higgins v. Colorado" on Justia Law

At issue in this case were questions involving what a trial court could order when a juvenile seeks a reverse-transfer of her criminal case from trial court to juvenile court. The district attorney directly filed a criminal complaint against defendant Sienna Johnson in trial court, treating her as an adult and charging her with two counts of conspiracy to commit first-degree murder. Defendant requested a reverse-transfer hearing, and the trial court granted her request. The State appealed, arguing that C.R.S. 19-2-517(3)(b)(VI) (the reverse-transfer statute) required a trial court to evaluate the petitioner's mental health. The DA requested access to defendant's mental health and psychological records and requested a court-ordered mental health assessment. Defendant responded that she should not have to produce the records because she had not waived her psychotherapist-patient privilege in her request for a reverse-transfer, and the statute did not give the trial court authority to order an assessment. The trial court ruled in favor of the DA on both counts. The Supreme Court concluded after review: (1) nothing in the reverse-transfer statute stated that a juvenile waived her psychotherapist-patient privilege by requesting a reverse-transfer hearing, so the trial court could not order her to produce her mental records; and (2) nothing in the statute gave the trial court explicit authority to order the mental health assessment. The case was therefore remanded for further proceedings. View "Johnson v. Colorado" on Justia Law

Minor admitted a violation of grand theft from the person of another, with a stipulated restitution of $20. Minor was ordered to the Correctional Academy for 12 months, consisting of six months of confinement and six months of aftercare under the supervision of probation. It was ordered that Minor could be returned to the Correctional Academy for a one-time remediation of 30 days at any time during the aftercare component due to a violation of probation or program rules. In the published portion of the opinion, the court held that the 30-day remediation violated the statutory protections afforded in the Welfare and Institutions Code as it permitted the probation officer to determine a violation of probation without notice to Minor and an opportunity to be heard. The court further held that it was impermissible for the juvenile court to impose a $50 “Facilities Assessment” pursuant to Government Code section 70372, subdivision (a). The court vacated the sentence and remanded for resentencing. View "In re Gabriel T." on Justia Law