Justia Juvenile Law Opinion Summaries

Petitioner Josh Sanchez was adjudicated a juvenile sex offender. He petitioned against the superior court's release of his offender information to the King County Sheriff's Office when he was released back into the community. Washington law mandated that the local authorities notify the community of the offender's release and potential risk that the offender posed. The Supreme Court held that the juvenile court could release the evaluation of petitioner that resulted in his receiving offender status, and that it was not a violation of his rights to do so. View "Washington v. Sanchez" on Justia Law

Appellant, a juvenile, admitted to conduct that would constitute felony sexual battery if committed by an adult. The trial court subsequently ordered Appellant to register as a sex offender. Appellant appealed, arguing insufficient evidence supported the court's finding that he was likely to repeat a sex offense. The court of appeals affirmed. The Supreme Court reversed, holding (1) a juvenile may only be ordered to register as a sex offender if, after an evidentiary hearing, the trial court expressly finds by clear and convincing evidence that the juvenile is likely to commit another sex offense; and (2) the trial court erred in placing Appellant on the registry where its order was neither issued in connection with an evidentiary hearing, nor accompanied by any findings. View "N.L. v. State" on Justia Law

Defendant, who was seventeen years old at the time, was charged with several counts of felony drug possession. Defendant pleaded guilty to one count of criminal possession of a controlled substance in the third degree and was sentenced to five years in prison plus two years of post-release supervision. Defendant appealed, arguing that the sentencing court erred in failing to address the question of youthful offender treatment at sentencing. The appellate division affirmed, concluding that Defendant waived his right to be considered for youthful offender treatment by failing to request he be treated as a youthful offender. At issue on appeal was N.Y. Crim. Proc. Law 720.20(1), which provides that, where a defendant is eligible to be treated as a youthful offender, the sentencing court must determine whether he is to be so treated. The Supreme Court reversed, holding that the statute requires that there be a youthful offender determination in every case where the defendant is eligible even if the defendant fails to request the determination or agrees to forgo it as part of a plea bargain. Remitted for a determination of whether Defendant was a youthful offender. View "People v. Rudolph" on Justia Law

A minor was questioned outside his home by a special agent of the police department, accompanied by a DCFS child protection worker, in the presence of the child’s mother and stepfather. After the interview, a petition for adjudication of wardship was filed, alleging that the minor was delinquent for having committed aggravated criminal sexual abuse concerning a young girl. The court suppressed the minor’s inculpatory statements after it was alleged that Miranda warnings had not been given. The appellate court dismissed, stating that it lacked jurisdiction. Although interlocutory appeals are allowed, in criminal cases, from the granting of suppression motions, there is no such provision in juvenile matters. The Illinois Supreme Court remanded after exercising its constitutional rulemaking authority to modify procedural Rule 660(a), which previously incorporated into minor proceedings criminal appeals rules only as to final judgments, to allow the state to take an interlocutory appeal. Since the 1998 Juvenile Justice Reform Amendments, virtually all of the protections of the criminal justice system are afforded to juveniles, and the law has moved toward protecting the public and holding minors more accountable. The state has the same interest in appealing a suppression order in a juvenile case as it does in a criminal case. The court declined to turn the matter over to the rules committee. View "In re B.C.P." on Justia Law

Appellant was indicted for the robbery and murder of Caesaro Gomez. Appellant, who was sixteen years old at the time of the crimes, was tried as a youthful offender and found guilty by a circuit court jury of murder, first-degree robbery, and intimidating a participant in the legal process. Appellant was sentenced to life imprisonment. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court did not abuse its discretion in denying Appellant's motion to strike for cause; (2) Appellant's argument regarding the validity of Ky. R. Crim. P. 9.40 was unpreserved for appellate review; and (3) the trial court did not err in sentencing Appellant. View "Grider v. Commonwealth" on Justia Law

Chicago police responded to a street fight. One yelled “police, stop, stop,” but M.I., then 16, fired multiple gunshots in their direction. A petition to have M.I. adjudicated delinquent was filed, and the state successfully moved to designate the proceedings as an “extended jurisdiction juvenile prosecution.” M.I. waived his right to a jury trial. After adjudicating him delinquent the circuit court sentenced him for aggravated discharge of a firearm, to an indeterminate period in the juvenile division of the Department of Corrections, to end no later than his twenty-first birthday. The court also imposed a 23-year adult sentence, stayed pending successful completion of the juvenile sentence. The appellate and supreme courts affirmed. M.I. argued that the hearing on designation as an extended jurisdiction juvenile proceeding was not held within the statutory time period, but the supreme court held that the statute is directory rather than mandatory. M.I. raised a constitutional vagueness challenge to the statutory provision that a stay of an adult sentence may be revoked for violation of the “conditions” of a sentence. Such a stay was part of the original sentence, and the state is seeking revocation based on a subsequent drug offense, but this was not the provision under which revocation was sought, so M.I. lacked standing for the challenge. M.I. also claimed that there was a due process violation in imposing a 23-year adult sentence, citing Apprendi v. New Jersey, 530 U.S. 466 (2000). The court found no Apprendi violation, noting that the extended jurisdiction juvenile statute is dispositional rather than adjudicatory. View "In re M.I." on Justia Law

Petitioner pleaded guilty to entering without breaking. The circuit court ordered Petitioner to be placed at the Anthony Center for Youthful Offenders. The warden later determined Petitioner was unfit to continue his placement at that facility, and Petitioner was transferred to jail. After a hearing to determine if the warden abused his discretion in removing Petitioner from the Anthony Center, the circuit court reinstated Petitioner's original one to ten year prison sentence and ordered that Petitioner not be given any credit towards the sentence for the time served at the Anthony Center. The Supreme Court affirmed in part and reversed in part, holding that the circuit court (1) did not err in upholding the warden's decision to expel Petitioner from the Anthony Center; but (2) erroneously denied Petitioner's request for credit for time served. Remanded. View "State v. Fitzsimmons" on Justia Law

Appellant Michael Herring was 16 years old when he was arrested for, and charged with, aggravated robbery. Because he was a juvenile, he was given his Miranda warnings by a magistrate. There was conflicting testimony as to whether two armed police officers were present when appellant was given these warnings. After the warnings, appellant was questioned by two police officers, and he confessed to the charged robbery, as well as other robberies and burglaries. The confession was reduced to writing by one of the officers, and appellant signed it. At trial, appellant filed a motion to suppress the signed statement, and argued, among other things, that the statement was taken in violation of Family Code Section 51.095 because armed law-enforcement officers were present when he was given the magistrate's warnings. The motion was denied, and a jury found appellant guilty, sentencing him to 20 years' confinement. Appellant appealed and asserted that the trial court erred in denying the motion to suppress. The court of appeals affirmed appellant's conviction. Appellant argued one issue to the Supreme Court: whether Section 51.095(a)(1)(A) permitted law-enforcement officers to be present when a juvenile is initially read his rights. The Court concluded that Section 51.095(a)(1)(A) does not prohibit the presence of law-enforcement officers, and accordingly affirmed. View "Herring v. Texas" on Justia Law

The State appealed a juvenile court order adopting a judicial referee's findings of fact and order dismissing the State's petition alleging M.H.P. was a delinquent child. The State filed a petition alleging M.H.P. was a delinquent child who committed gross sexual imposition. The judicial referee found M.H.P. was not in need of treatment or rehabilitation as a delinquent child. The judicial referee explained he previously found beyond a reasonable doubt that M.H.P. committed the delinquent act of gross sexual imposition and stated, "Although this fact alone would be sufficient to sustain a finding of a need for treatment and rehabilitation, there was a substantial amount of evidence to the contrary." Based on these findings, the judicial referee dismissed the petition. The juvenile court adopted the judicial referee's findings and order, dismissed the proceeding and concluded the issue of M.H.P. registering as a sexual offender did not need to be addressed. Upon review, the Supreme Court concluded that the Double Jeopardy Clause of the Fifth Amendment of the United States Constitution barred the State from appealing the juvenile court's order. The Supreme Court therefore affirmed the dismissal of the juvenile court's findings. View "Interest of M.H.P." on Justia Law

Tribal authorities of the Tohono O'odham nation charged LKAV, age 17, with murder in May 2009. In November 2011, the United States moved to commit LKAV pursuant to 18 U.S.C. 4241 to an adult medical facility for psychiatric treatment. The court held that when the United States charges a juvenile with an act of juvenile delinquency under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-42, the district court must follow 18 U.S.C. 5037(e) if it committed the juvenile for a study of the juvenile's competency to stand trial. Because the district court in this case instead committed LKAV under 18 U.S.C. 4241(d), the court reversed the judgment. View "United States V. LKAV, Juvenile Male" on Justia Law