Justia Juvenile Law Opinion Summaries

Pierce Township Officer Homer responded to a call from S.L.’s mother and “smelled smoke.” S.L.’s mother stated that her teenage son had set fires in the house and that she had found smoldering Popsicle sticks in his bedroom. Homer entered S.L.’s bedroom. Popsicle sticks were not visible, but S.L. allegedly admitted that he had the fire. Homer asked whether he was afraid that the house might catch fire. S.L. responded, “I really don’t care.” Homer arrested S.L. for aggravated arson, transported him to the Juvenile Detention Center, and prepared a complaint charging S.L. as delinquent. Bartley, a deputy clerk, signed the complaint, attesting that Homer had taken an oath in his presence, but never administered the oath. S.L. appeared 12 hours later before Judge Wyler, who scheduled the pre-trial hearing and ordered continued detention pending psychological evaluation. S.L. was released a week later; the charge was dismissed. S.L. sued. Concerning claims against Homer under 42 U.S.C. 1983, the district court held that a genuine dispute of material fact existed on probable cause for arrest. Concerning Bartley, the court held that there is no duty for a detention clerk to make an independent assessment of probable cause and that a genuine dispute of material fact existed as to whether Bartley had legal authority to administer oaths. The court denied summary judgment for the township because the judge did not make a probable-cause determination. There was insufficient evidence that police training was inadequate. The court denied summary judgment based on a qualified immunity defense. The Sixth Circuit affirmed. View "S.L. v. Pierce Twp. Bd. of Trustees" on Justia Law

The Jefferson Davis County Youth Court held J.P. (minor) in a juvenile detention facility for 103 days, then in the Jefferson Davis County Jail for thirty days more when J.P. attained age eighteen. J.P. was never adjudicated delinquent. No hearing was held on the question of his delinquency. After more than four months in custody, he was released. The court nevertheless ordered his parents to pay the nearly $10,000 cost of J.P.'s 103-day confinement in juvenile detention. On appeal, the Supreme Court reversed the judgment of the youth court and rendered judgment in favor of the parents: the State cannot charge the parents of a minor for his detention when that detention was never legally justified. View "In the Interest of J.P. a Minor: R.P. and D.O. v. Mississippi" on Justia Law

The People filed a petition alleging that petitioner, who had recently turned 13 years old, committed assault with a deadly weapon and assault by means likely to produce great bodily injury. Petitioner denied the allegations and the juvenile court released him to his mother. Petitioner subsequently filed a petition for a writ of mandate to compel the juvenile court to vacate its order finding him competent to stand trial. The court found that the juvenile court applied the standard of competency applicable to adults under Penal Code sections 1367 and 1368, rather than the standard of competency applicable to minors under Welfare and Institutions Code section 709. The juvenile court also made no finding, by a preponderance of the evidence or otherwise, regarding petitioner's ability to consult with counsel and assist in preparing his defense. Accordingly, the court granted the petition and vacated the juvenile court's order finding petitioner mentally competent. View "Bryan E. v. Super. Ct." on Justia Law

Antonio T., a seventeen-year-old high school student, was taken to the principal's office because he was suspected of being under the influence of alcohol. The assistant principal questioned Antonio about his possession of alcohol in the presence of a deputy sheriff. Antonio admitted that he had brought alcohol to school, where he drank it. At the principal's request, the deputy administered a breath alcohol test to Antonio, which was positive for alcohol. After administering the test, the deputy advised Antonio of his right to remain silent, and Antonio declined to answer the questions. Antonio was charged with the delinquent act of possession of alcohol by a minor. He filed a motion to suppress the statements he made to the assistant principal because his statements were elicited without a knowing, intelligent, and voluntary waiver of his right to remain silent. The district court denied his motion, which was affirmed by the Court of Appeals. The Supreme Court reversed both the district court and the Court of Appeals: although a school official may insist that a child answer questions for purposes of school disciplinary proceedings, any statements elicited by the official may not be used against the child in a delinquency proceeding unless the child made a knowing, intelligent, and voluntary waiver of his or her right to remain silent. Because the State failed to prove that Antonio effectively waived this right, his statements were inadmissible in the delinquency proceeding. View "New Mexico v. Antonio T." on Justia Law

Juan A. was charged with one count of misdemeanor battery on school property; resisting an officer; disturbing the peace; and felony threatening a public officer or employee. At the time of the adjudication hearing, the prosecution's motion to dismiss the misdemeanor battery count was granted. At the end of the hearing, the court made true findings only on the resisting an officer charge and on the disturbing the peace charge. Juan A. was placed on formal probation, then appealed. On appeal, Juan argued there was not sufficient evidence to support the true findings on either of the remaining counts. After careful examination of the record, the Court of Appeal agreed with the Minor that the prosecution failed to prove the elements of either offense. Thus the court should not have made true findings on those charges. View "In re Juan A." on Justia Law

Dana Fuller appealed a Family Court decision denying her petition for expungement of her juvenile record because she had committed three traffic violations as an adult. In this case, the Family Court held that Fuller's violations of Title 21, which governs motor vehicles, were "subsequent . . . adult convictions." But the Family Court has reached different conclusions in other cases as to whether a traffic violation under Title 21 of the Delaware Code is a subsequent adult conviction that precludes expungement of a juvenile record. On appeal, Fuller argued that Title 21 offenses were not "subsequent adult convictions" and the denial of her expungement was therefore erroneous. After review, the Supreme Court held that a "subsequent adult conviction” is a later conviction only for a crime in violation of Title 4, 7, 11, 16, or 23 of the Delaware Code, and does not include a violation of Title 21. Accordingly, we reverse the Family Court's decision. View "Fuller v. Delaware" on Justia Law

Defendant was 15 years old and was a ward of the state, living in a residential treatment facility when he was charged with three counts of aggravated criminal sexual assault against a staff member. Pursuant to the Illinois automatic transfer statute (705 ILCS 405/5-130), his case was transferred from juvenile court to criminal court, where he was tried as an adult, convicted by a jury of all three counts, and sentenced to a total of 36 years in prison. The appellate court remanded for a new trial, holding that the circuit court had erred by admitting defendant’s confession. The court also concluded that evidence of the victim’s sexual history was admissible on remand under the “constitutional necessity” exception to the state rape shield statute (725 ILCS 5/115-7(a)). The Illinois Supreme Court reversed the appellate court’s exclusion of defendant’s confession and determination that evidence of the victim’s sexual history is admissible under an exception to the rape shield statute, rejected his ineffective assistance claim, and upheld the constitutionality of the automatic transfer statute. The court remanded to the appellate court for its initial consideration of defendant’s excessive-sentence claim. View "People v. Patterson" on Justia Law

L.D. was charged with the commission of a felony-grade delinquent act of unauthorized use of a movable. Although La.Ch.C. art. 854(A) required in this instance that L.D. appear to answer the delinquency petition within five days of filing because he was continued in custody, the district court set the answer hearing for the next available court date dedicated to juvenile matters, 27 days later. L.D. appeared at that time, objected to the untimeliness of the hearing, and asked for his release from custody and for dismissal of the delinquency petition. The juvenile judge found, consistent with a policy of that court, that the court’s scheduling constraints constituted "good cause" for the delay under La.Ch.C. art. 854(C). The court therefore declined to dismiss the petition and release L.D. from custody, and the juvenile did not seek immediate review of that ruling. The court adjudicated L.D. delinquent 21 days later, within the 30 days from the answer hearing afforded by La.Ch.C. art. 877(A). On appeal, L.D. contended that his adjudication hearing was nevertheless untimely and that the petition should therefore have been dismissed because each step in delinquency adjudication process "should be seen as carefully and closely placed, like dominoes in a row, and that by wrongly delaying the answer hearing, the juvenile court judge triggered a cascade, a rippling effect, that ended in an adjudication that should be viewed as untimely as well." The court of appeal found that the juvenile judge erred in denying L.D.’s motion for release based on failure to timely hold the answer hearing. The Supreme Court affirmed: "[w]e [. . .] agree with the court of appeal majority that the legislature did not subscribe to the rippling effect advocated by L.D., such that the slightest perturbation in the steady march of various time limits through the process results inexorably in the dismissal of a delinquency petition. The court of appeal noted, and all parties agree, that La.Ch.C. art. 854 specifies no remedy when the time afforded for an answer hearing is exceeded without good cause. The provisions of the Children’s Code governing delinquency proceedings otherwise contain several explicit time limits. [. . .] Only when the time afforded by La.Ch.C. art. 877 to commence the delinquency adjudication following the answer hearing is exceeded must the court dismiss the petition at the request of the juvenile." View "Louisiana in the Interest of L.D." on Justia Law

About 25 years ago, petitioners Russell McNeil and Herbert Rice Jr. were tried as adults and convicted of aggravated first degree murder for crimes committed while the petitioners were both a little over 17 years old. They were each given the mandatory minimum sentence for that crime-life in prison without the possibility of early release. In 2012, the United States Supreme Court issued its opinion in "Miller v. Alabama," (132 S. Ct. (2012)). Relying on "Miller," petitioners sought relief from their sentences on collateral review through personal restraint petitions (PRPs). While the PRPs were pending before the Washington Supreme Court, the legislature passed and the governor signed Second Substitute Senate Bill 5064, "the Miller fix." The State filed a motion to dismiss the PRPs, arguing the Miller fix made it impossible for petitioners to meet their threshold burden of showing they had suffered actual and substantial prejudice based on a constitutional error. The Washington Court denied the State's motion and deny the PRPs. View "In Re Pers. Restraint of McNeil" on Justia Law

Defendant, a ward of the juvenile court, appealed his conviction for charges related to his participation in a gang. The court reversed the convictions for two counts of active participation in a criminal street gang (counts 3 & 6) because substantial evidence did not establish that defendant promoted, furthered, or assisted in the perpetration of felonious conduct by at least two gang members. View "People v. Johnson" on Justia Law