Justia Juvenile Law Opinion Summaries

Daniel Paul Sansone, the defendant-appellant, was convicted for being a felon in possession of a firearm. He was sentenced to 46 months of imprisonment, the upper end of the sentencing guideline range. Sansone challenged the procedural integrity and substantive reasonableness of his sentence. The United States Court of Appeals for the First Circuit reviewed his claims.Sansone had argued that his criminal history score was erroneously inflated due to the inclusion of his juvenile adjudications, asserting that his commitment to the Massachusetts Department of Youth Services (DYS) was not a sentence of confinement. The court rejected this argument, noting that prior case law had upheld the inclusion of such adjudications as constituting sentences of confinement.Sansone also claimed there was insufficient evidence to support the conclusion that his juvenile adjudications resulted in confinement for at least sixty days, which was necessary for the assignment of criminal history points under the United States Sentencing Guidelines (USSG). The Court of Appeals found that Sansone could not show a plain error in this regard, as the record was ambiguous and did not allow for a clear determination of the length of his confinement.Regarding the substantive reasonableness of his sentence, Sansone argued that the sentencing court had overstated the seriousness of his past criminal record and failed to adequately consider his personal history. The Court of Appeals disagreed, finding that the sentencing court had considered all relevant factors, and Sansone's real complaint was about the weight given to certain factors, not their consideration. The court upheld the sentence, affirming the district court's decision. View "US v. Sansone" on Justia Law

In this case, the Supreme Court of the State of Montana upheld the decision of the Montana First Judicial District Court, Lewis and Clark County, committing the appellant, C.M., a youth, to the custody of the Department of Corrections for placement in a state youth correctional facility until the age of 18. The appellant was charged with sex offenses against three of his high school classmates and he appealed the decision on the grounds that he was denied the right to effective assistance of counsel when his attorney failed to make objections to the admission of various hearsay statements.The court concluded that the appellant's counsel's failure to object to the admission of hearsay statements did not result in substantial prejudice. The court noted that the state presented sufficient admissible evidence to the jury that proved the same facts as the prior consistent statements and bus records. Furthermore, the court found that the appellant's counsel vigorously challenged the complaining witnesses' testimony by highlighting inconsistencies and gaps in their testimony, as well as aspects of the investigation. As a result, the court found that the appellant failed to demonstrate that he was prejudiced by any alleged deficient performance by his counsel and affirmed the lower court's decision. View "Matter of C.M" on Justia Law

In this case, the Supreme Court of Georgia had to determine whether a unit-of-prosecution analysis or a required evidence analysis should be used to address the question of merger as to one count of aggravated child molestation and two counts of child molestation. Tony Shropshire was convicted of aggravated child molestation, two counts of child molestation, incest, and first-degree cruelty to children, based on incidents that occurred in 2001 with his five- or six-year-old niece. Shropshire argued on appeal that the two child molestation counts should have merged into the aggravated child molestation conviction. The Court of Appeals applied a unit-of-prosecution analysis and agreed, merging the counts and vacating Shropshire's convictions and sentences for aggravated child molestation and child molestation. The Supreme Court of Georgia vacated this part of the Court of Appeals's judgment and remanded the case. The Supreme Court held that a unit-of-prosecution analysis should be applied to determine whether the two counts of child molestation (the same crime) merge. However, as child molestation and aggravated child molestation are different crimes, a required evidence analysis should be applied to determine whether these two different crimes merge. The Court of Appeals erred in applying a unit-of-prosecution analysis rather than a required evidence analysis to this question. The case was remanded for the Court of Appeals to apply the correct analyses. View "THE STATE v. SHROPSHIRE" on Justia Law

This case from the Supreme Court of Iowa involves a juvenile, I.S., who was charged with sexual exploitation of a minor and possession of child pornography. The juvenile court initially waived its jurisdiction over the case, allowing it to be tried in the district court. However, the juvenile court later vacated its waiver and reclaimed jurisdiction over the case. The State sought a review of the juvenile court's decision to vacate its earlier order, arguing that the juvenile court no longer had jurisdiction or authority to modify or vacate the waiver order once it had been issued.The Supreme Court of Iowa held that the juvenile court did not have the authority to reclaim jurisdiction over the case after it had waived it to the district court. The court found that there was no provision in Iowa law for such a "revocation of waiver." The court reasoned that once a case has been transferred or waived to another court, the transferring court loses jurisdiction over the parties. The court also noted that allowing a juvenile court to reclaim jurisdiction could lead to disruption of proceedings and friction between the district and juvenile courts.Therefore, the court sustained the State's writ, vacated the juvenile court's revocation of its waiver of jurisdiction, and remanded the case, with the expectation that any further proceedings would occur in the district court. View "State of Iowa v. Iowa Juvenile Court for Plymouth County" on Justia Law

In this case from the Supreme Court of Iowa, the appellant, David Gordon, a minor at the time of committing his crimes, was charged with theft in the first degree and willful injury resulting in bodily injury. He pleaded guilty and was sentenced to ten years in prison for the theft conviction and five years for the assault conviction, with the sentences to run concurrently. Gordon appealed the sentence and also filed a motion requesting reconsideration of the sentence under Iowa Code § 902.4. The district court reconsidered the sentence and placed Gordon on probation for up to five years. Gordon then filed a petition for writ of certiorari challenging his resentencing, arguing that the district court had abused its discretion by not granting him a deferred judgment in its initial sentencing, and then by wrongly concluding that it lacked the authority to do so under § 902.4 when resentencing him.The Supreme Court of Iowa affirmed the district court's decisions. The court held that the district court did not abuse its discretion in the initial sentencing. It found that the district court had considered and weighed the arguments for and against a deferred judgment, and had thoroughly explained its reasoning for the sentence imposed. As for Gordon's argument about the district court's power to defer judgment when reconsidering a sentence under § 902.4, the Supreme Court held that a deferred judgment involved more than a sentence. It involved the deferring of a judgment adjudicating guilt as well as a sentence. The court concluded that the district court correctly interpreted its authority under § 902.4 when it determined that it could not defer judgment when reconsidering Gordon's sentence. Therefore, the court affirmed Gordon's conviction and sentence and annulled the writ of certiorari. View "State of Iowa v. Gordon" on Justia Law

In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

In the case before the Supreme Court of Ohio, the issue was the quantum of evidence required to satisfy the probable-cause standard for determining whether a juvenile-court offender may be bound over to adult court. The case arose from an incident where a juvenile, E.S., was in a stolen car during a police chase, with his friend E.M., who was driving. After the car crashed, E.M. was found dead from a gunshot wound. A gun was found under the car’s passenger seat where E.S. had been seated, and E.S.'s DNA was found on the trigger and the grip of the gun. A bullet that had been fired from the gun was found in the driver's side front door. E.S. was charged in juvenile court with multiple offenses relating to the stolen car, the gun, and E.M.’s death.The juvenile court found probable cause for some charges but not for involuntary manslaughter or reckless homicide. The state appealed the juvenile court's decision. The Court of Appeals affirmed the juvenile court’s judgment. The state then appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the judgment of the Court of Appeals. The court held that the state had presented sufficient evidence to establish probable cause to believe that E.S. had committed the offense of involuntary manslaughter. The court found that the state’s evidence, both circumstantial and direct, was sufficient to establish probable cause. The court held that the juvenile court and the Court of Appeals had erroneously held the state to a higher burden than required for establishing probable cause in a bindover proceeding. The case was remanded back to the juvenile court for further proceedings. View "In re E.S." on Justia Law

C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law

A jury found that Child-Respondent Antonio M. (Child) committed felony murder, attempted armed robbery, conspiracy to commit armed robbery, child abuse, and aggravated assault with a deadly weapon. The State charged Child as a participant in the fatal shooting of Fabian Lopez (Victim) at Frenger Park in Las Cruces. Uncontested evidence at Child’s adjudicatory hearing established that M.M. and two other participants killed Victim in his car in the course of a drug deal. During opening statements and closing arguments, defense counsel’s theory of the case was that the State could not present sufficient evidence of Child’s participation in the crime and that the robbery and resulting homicide were unplanned and unintended results of a simple drug purchase. Defense counsel did not challenge Child’s presence in the car that transported M.M. to and from the park. On appeal, Child challenged the admission of three in-court identifications under federal and state due process. The Court of Appeals reversed for plain error, finding that the in-court identifications were impermissibly suggestive and thereby violated Child’s due process right to a fair trial under the Fourteenth Amendment of the United States Constitution. The New Mexico Supreme Court determine that identity was not at issue regarding the testimony of the three relevant witnesses and thus that Child’s due process rights were not violated by the relevant in-court identifications. Accordingly, the Supreme Court reversed the Court of Appeals. View "New Mexico v. Antonio M." on Justia Law

The Louisiana Supreme Court granted the State’s application to review the court of appeal’s determination that the State failed to prove that 16-year-old D.W. was the person who entered a sheriff’s vehicle and stole firearms from inside it, and therefore that the evidence was insufficient to support the delinquency adjudication for burglary involving a firearm, La. R.S. 14:62, and theft of a firearm, La. R.S. 14:67.15. After reviewing the record, the Supreme Court found the State presented sufficient evidence that D.W. was a principal, in accordance with La. R.S. 14:24, to these felony-grade delinquent acts regardless of whether he personally entered the vehicle and took the firearms that were inside it himself. Therefore, the Court reversed the ruling of the court of appeal and reinstated the delinquency adjudication and dispositions imposed by the juvenile court, which were then affirmed. View "Louisiana in the interest of D.W." on Justia Law