Justia Juvenile Law Opinion Summaries

The girl, then 15, was charged with misdemeanor battery for allegedly striking a female classmate in the face and chest. A prosecution offer to recommend a continuance under supervision in return for a guilty plea was rejected and the case proceeded to trial. The victim and a security guard who had intervened testified. The accused minor testified that she had acted in self-defense. The trial judge entered a finding of guilt. The probation officer and the prosecution recommended probation, but defense counsel asked for a continuance under supervision. The judge said that the Juvenile Court Act precludes supervision for minors without the permission of the State’s Attorney, that the “approval provision” does not apply in the adult criminal system, and that the approval provision unconstitutional. The judge placed the minor on supervision, over the state’s objection. The Illinois Supreme Court reversed the supervision order as void and vacated the finding of unconstitutionality. The Juvenile Court Act has been interpreted to require that the possibility of supervision be considered before proceeding to a finding of guilt and adjudication as to delinquency. Here, supervision was not requested before the finding of guilt, so any objection by the prosecutor had become irrelevant. The minor lacked standing to raise the constitutional issue. The girl claimed ineffective assistance of counsel because she did not know she was giving up the opportunity for supervision by rejecting the plea offer, and that neither her attorney nor the court knew that supervision had to be requested before a finding of guilt. The court found that the minor had been prejudiced and remanded to allow her to request supervision at the appropriate time. Should the state object, a challenge to the validity of the approval provision could properly be raised.View "In re: Danielle J" on Justia Law

In 2010, two Fare Enforcement Officers entered a train car at the Rainier Beach station and instructed all passengers to present proof of fare. When FEO Willet asked fifteen-year-old K.L.B. and his two companions to present proof of fare payment, they gave him their bus transfers. FEO Willet informed them that while bus transfers used to be valid on the light-rail, they were no longer accepted. The three young males were instructed by FEO Willet to exit the train at the next station. The FEOs asked the three males for identification once they exited the train. All three were either unable or unwilling to provide identification. K.L.B. was temporarily detained at the Othello station. The King County Sheriff's Office was called to assist in identifying K.L.B. and his companions so they could potentially be cited for fare evasion. Deputy Adams then asked K.L.B. to identify one of his male companions. He responded that he did not know his companion's full name and that he: knew him only as '"Marty."' Deputy Adams returned to the station and used a computer database to identify "Marty." There was an assault warrant out for "Marty's" arrest. K.L.B. was charged with two counts of making a false or misleading statement to a public servant under RCW 9A.76. 175. K.L.B. was found guilty of making a false statement to FEO Willet (count II). He was found not guilty of making a false statement to Deputy Adams (count I). K.L.B. appealed to Division One of the Court of Appeals, which affirmed his conviction. K.L.B. argued that a Sound Transit FEO was not a "public servant" as defined in RCW 9A.04.110(23). He also argued that the definition of "public servant" was unconstitutionally vague and that to convict a person of making a false or misleading statement to a public servant, the State must prove that the defendant knew the statement was made to a public servant. The Court of Appeals affirmed the trial court's conclusion that under the statute, FEO Willet was a public servant at the time K.L.B. made the false statement. The Supreme Court held that under these circumstances, because FEOs are not government employees, are not officers of government, and do not perform a governmental function, they are not "public servants" as defined by the statute. View "Washington v. K.L.B." on Justia Law

Anthony Geltz was prosecuted as a juvenile and adjudicated delinquent for sexual abuse in the second degree for an offense he committed when he was fourteen years old. After Geltz turned eighteen, the State petitioned to have him declared a sexually violent predator (SVP) under Iowa Code 229A.2(11). The district court ordered Geltz confined as an SVP based on Geltz's previous offense. The Supreme Court reversed, holding (1) a juvenile adjudication does not constitute a predicate conviction required to commit an offender as an SVP pursuant to section 229A.2; and (2) therefore, the district court erred in committing Geltz as an SVP solely on the basis of his juvenile adjudication for the offense he committed at age fourteen.View "In re Detention of Geltz" on Justia Law

The State charged Petitioner with two counts of first-degree murder and associated offenses. The State filed a motion in the juvenile court seeking to unseal and release Petitioner's juvenile records to assist in the prosecution. The juvenile court issued an order broadly unsealing and releasing the records for "use in the prosecution." The Supreme Court granted Petitioner's petition for extraordinary relief, holding (1) a district attorney is not statutorily authorized to inspect a defendant's sealed juvenile records to obtain information that will be used against him or her in a subsequent proceeding; and (2) therefore, the juvenile court manifestly abused its discretion by granting the State's motion to inspect Petitioner's sealed juvenile records.View "Clay v. Eighth Judicial Dist. Court" on Justia Law

Marshall pled guilty to receiving child pornography (18 U.S.C. 2252(a) and (b)) from the time he was 15 until he was 20 years old. The district court varied downward from the guideline range and sentenced him to five years in prison, the mandatory minimum sentence for the offense, expressing concerns about the perceived harshness of that sentence. Marshall has a rare physiological condition, Human Growth Hormone Deficiency, which he believes entitles him to the Eighth Amendment protections accorded to juveniles. Although diagnosed with an I.Q. score of 87 and a mental age of 15, Marshall attended a community college part-time for four semesters, pursuing a career as a lab technician and paying his own tuition. He worked as a machine operator for a commercial bakery. He owned a car and had a credit card. He claimed that he felt like he was viewing images of his peers and that he often felt like a 15 or 16-year-old individual because of his small frame and stature. The Sixth Circuit affirmed, stating that Marshall was an adult at the time of his crimes.View "United States v. Marshall" on Justia Law

Police officers were dispatched in response to reports of an armed subject pointing a rifle at several people from the window of a light beige or tan vehicle. After Defendant Leticia T. (Child) and children passengers were removed and detained, the officers conducted a warrantless search of the interior and trunk of the vehicle. The district court held that the warrantless search was justified by exigent circumstances. The Court of Appeals reversed the district court, ruling that the possibility of a person hiding in the trunk of a vehicle did not constitute exigency. The issue on appeal to the Supreme Court centered on the Court of Appeals' reversal. The Supreme Court conclude after a review of the district court record was that when police officers have probable cause and exigent circumstances to believe that an armed subject pointed a rifle at other individuals from a vehicle, officers may search the cab and the trunk of that same vehicle for the rifle. View "New Mexico v. Leticia T." on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown and fifteen-year-old Defendant, robbed two victims in their home. The victims were killed during the robbery. Defendant was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Defendant to an aggregate sentence of 150 years, the same sentence imposed on Brown. The Supreme Court revised the 150-year sentence received by Brown and similarly exercised its constitutional authority to revise Defendant’s sentence, holding that Defendant’s sentence “foreswears altogether the rehabilitative ideal” and concluding that Defendant should total aggregate sentence of eight-five years imprisonment. View "Fuller v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown, robbed two victims in their home. The victims were killed during the robbery. Brown was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Brown to an aggregate sentence of 150 years, the same sentence imposed on Brown’s cohorts. The Supreme Court revised the 150-year sentence received by Brown, holding that Brown’s sentence “foreswears altogether the rehabilitative ideal,” and concluded that Brown should be sentenced to an enhanced sentence to a total aggregate sentence of eighty years imprisonment. View "Brown v. State" on Justia Law

The juvenile court took jurisdiction over A.J.C. for conduct that, if committed by an adult, would have constituted possession of a firearm in a public building, unlawful possession of a firearm, unlawful use of a weapon, and menacing. The question this case presented to the Supreme Court for review was whether the school-safety exception to the warrant requirement announced in "State ex rel Juv. Dept. v. M. A. D.," (233 P3d 437 (2010)), permitted a school principal to conduct a warrantless search of the youth’s backpack after the principal had seized the backpack from the youth. The juvenile court concluded that the search was permissible under the school-safety exception, and it denied youth’s pretrial motion to suppress. The Court of Appeals affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Oregon v. A. J. C." on Justia Law

The issue before the Supreme Court in this case centered on whether "Miller v. Alabama," (567 U.S. __ (2012)) applied retroactively in state collateral proceedings. Defendant Darryl Tate, whose mandatory life-without-parole sentence for a second-degree murder he committed as a juvenile became final in 1984, filed a motion seeking resentencing in light of Miller. The District Court denied his motion, but the Court of Appeal granted writs, remanding the matter for a sentencing hearing. The Louisiana Supreme Court granted writs to address the retroactivity of Miller to those juvenile homicide convictions final at the time Miller was rendered. Upon review, the Louisiana Court found Miller did not apply retroactively in cases on collateral review as it merely set forth a new rule of criminal constitutional procedure, which is neither substantive nor implicative of the fundamental fairness and accuracy of criminal proceedings. Therefore, the Court reversed the judgment of the Court of Appeal and reinstated the judgment of the District Court.View "Louisiana v. Tate" on Justia Law