Justia Juvenile Law Opinion Summaries

A.M.M.-H. was sentenced in an extended juvenile jurisdiction proceeding in which he was given both a juvenile sentence and an adult sentence. The adult sentence was stayed pending successful completion of his juvenile sentence. After A.M.M.-H. violated the terms of conditional release on his juvenile sentence the district judge revoked conditional release and ordered A.M.M.-H. to serve his adult prison sentence. The court of appeals affirmed the district court. The Supreme Court reversed, holding (1) in this case, the district judge had discretion to determine whether A.M.M.-H.’s violation of the terms of conditional release warranted revocation of the stay of the adult sentence; and (2) because the record was unclear as to whether the district judge knew he had discretion not to execute the adult sentence upon a finding of violation of the terms of A.M.M.-H.’s conditional release, the case must be remanded for reconsideration of the State’s motion to revoke. View "In re A.M.M.-H." on Justia Law

Minor Zachary Stringer was charged with the murder of his younger brother, Justin. The jury found Zachary guilty of the lesser-included offense of manslaughter. The trial court sentenced Zachary to twenty years, with ten years to serve and ten years of post-release supervision, with five years reporting. Zachary appealed his conviction and sentence, arguing: (1) the trial court erred by allowing multiple gruesome photographs of the victim and the crime scene into evidence; and (2) the trial court erred in denying his motion for judgment notwithstanding the verdict (JNOV). Finding no error, the Supreme Court affirmed Zachary's conviction and sentence.View "Stringer v. Mississippi" on Justia Law

The State charged appellant "Kevin R." with possessing a weapon on school grounds. Prior to his adjudicatory hearing before a family court judge, Appellant moved for a jury trial on the grounds the federal and state Constitutions guaranteed him the right to a jury trial. The judge denied the motion and proceeded to hear Appellant's case in a bench trial. Ultimately, the judge adjudicated Appellant delinquent and deferred sentencing until an evaluation of Appellant was completed. The sentencing hearing was conducted before a second family court judge, who sentenced Appellant to an indeterminate period of time not to exceed his twenty- first birthday. The judge then suspended the sentence and placed Appellant on probation until his eighteenth birthday. On appeal, Appellant contended the family court judge erred in denying his motion for a jury trial. Recently, the South Carolina Supreme Court held a juvenile did not have a constitutional right to a jury trial in adjudication proceedings. However, the Court's decision in that case was not dispositive as it was presented with additional arguments raised by Appellant and the Amici Curiae. After consideration of these issues, the Court adhered to its decision in the earlier case, and affirmed the family court. View "In the Interest of Kevin R." on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court.View "Idaho v. John Doe (2012-10)" on Justia Law

The trial court concluded that section 5-615 of the Juvenile Court Act, 705 ILCS 405/5-615, was unconstitutional, and ordered a continuance under supervision in a case involving a minor, rejecting a negotiated plea agreement. The minor had been the subject of multiple charges and had failed to appear for court dates. The Illinois Supreme court vacated. The provision at issue grants a State’s Attorney, among others, authority to object to the entry of an order of continuance under supervision in a juvenile case before a finding of guilt. The court noted that juvenile proceedings are fundamentally different from criminal proceedings, a difference which extends to the role of the state. The purposes and objectives of the Juvenile Court Act are protective in nature, to correct and rehabilitate, not to punish, and the Act lists the State’s Attorney among those who would undoubtedly be concerned with the children’s best interests. The State’s Attorney has a duty to see that justice is done not only to the public at large, but to the accused as well. In this case, the state exercised its authority under section 5-615 in accordance with that duty.View "In re Derrico G." on Justia Law

Defendant was convicted of first degree murder and sentenced to life imprisonment for a murder he committed when he was sixteen years old. More than fifteen years later, Defendant filed an amended postconviction motion challenging his life imprisonment sentence. The district court denied the motion. After Defendant appealed, the U.S. Supreme Court decided Miller v. Alabama, which held that the Eighth Amendment forbids a state sentencing scheme that mandates life in prison without the possibility of parole for a juvenile offender convicted of homicide. The Supreme Court reversed in this case, holding (1) the rule announced in Miller applied retroactively to Defendant; and (2) Defendant’s sentence was unconstitutional under Miller, and therefore, Defendant was entitled to be resentenced. Remanded. View "State v. Mantich" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree felony murder and other charges arising from three shootings. At the time of the shootings, Defendant was fifteen years old. Defendant was sentenced to two life terms without the possibility of parole for the murder counts. The Supreme Court affirmed Defendant’s convictions in all respects but vacated the sentences of life imprisonment without the possibility of parole, holding that the life imprisonment sentences were unconstitutional under Miller v. Alabama, in which the U.S. Supreme Court held that it is unconstitutional to sentence a juvenile convicted of a homicide to a mandatory sentence of life imprisonment without the possibility of parole.View "State v. Castaneda" on Justia Law

Responding to a report of underage drinking in a home, officers found a group celebrating eighth grade graduation. Police asked the teens to step outside individually for breathalyzer testing. Seven tested positive for alcohol. Police arrested them and notified their parents. In the morning, a juvenile worker arrived at the police station, and, after speaking with a judge, indicated that the children were to be detained for a court appearance the next day. At the regional juvenile detention center, the minors underwent routine fingerprinting, mug shots, and metal-detection screening. During a hygiene inspection and health screening, they were required to disrobe completely for visual inspection to detect “injuries, physical abnormalities, scars and body markings, ectoparasites, and general physical condition.” A same-sex youth worker observed the juveniles for several minutes from a distance of one to two feet, recording findings for review by an R.N. The minors were required to shower with delousing shampoo. They were released the following day. The charges were dropped. In a suit under 42 U.S.C. 1983, the district court granted partial summary judgment in favor of the juveniles, based on a “clearly established right for both adults and juveniles to be free from strip searches absent individualized suspicion” that negated a qualified immunity defense. The Sixth Circuit reversed, stating that no clearly established principle of constitutional law forbids a juvenile detention center from implementing a generally applicable, suspicionless strip-search policy upon intake into the facility.View "T. S. v. Doe" on Justia Law

Between December 11, 2011 and January 1, 2012, the Billings Police Department responded to more than 200 reports of vandalism. B.W., a youth, admitted to having committed acts of vandalism on December 22, 2011 and December 29, 2011. The youth court adjudicated B.W. a delinquent youth for having committed criminal mischief, common scheme and ordered B.W. to pay $78,702 in restitution, which represented the total damages sustained over the eleven-day vandalism spree. The Supreme Court reversed, holding that the youth court erred in concluding that B.W. was jointly and severally liable for the full amount of restitution for damages where the State did not establish that B.W. was accountable for the crimes of others in which Defendant did not participate. Remanded for a new restitution hearing.View "In re B.W." on Justia Law

Officer Woelkers saw 15-year-old J.G. walking across a parking lot toward his brother, D.G. Woelkers parked his patrol vehicle, without turning on lights or siren, and “casually” approached the brothers. He was wearing his uniform. J.G. said they were going to a party. Officer Klier arrived in his patrol vehicle to “assist.” Woelkers asked D.G. for identification, and D.G. gave him a Honduran identification card. J.G. stated that he had no identification and gave a name. J.G. Woelkers ran a check and learned that no California driver’s license or identification card had issued to either boy. The boys consented to a pat-down and the officers found nothing illegal. Meanwhile, two more officers arrived, displaying a gun. J.G. agreed to a search of his backpack. Woelkers located a semiautomatic pistol inside. The D.A. filed a petition under Welfare and Institutions Code section 602(a) alleging felony possession of a concealed firearm by a minor. J.G. first admitted that allegation, then successfully moved to withdraw his plea, and moved to suppress the pistol from being introduced into evidence. The juvenile court denied the motion. The court of appeal reversed. The totality of the circumstances would have conveyed to a reasonable person—juvenile or adult—that he was not free to refuse the request. Woelkers clearly conveyed that he suspected the brothers of unlawful activity. He asked them whether they had anything “illegal,” conducted a records check, and searched them, physically restraining them, while the police presence and show of force grew. View "In re J.G." on Justia Law