Justia Juvenile Law Opinion Summaries

G.W. was taken into custody in the District of Columbia on a delinquency matter. Although released in that matter, the trial court ordered his detention under the Interstate Compact for Juveniles (ICJ) to be picked up by Virginia authorities on a different juvenile matter. When Virginia authorities did not take custody, the trial court dismissed the ICJ matter, but the District of Columbia Department of Youth Rehabilitation Services (DYRS) continued to detain G.W., interpreting the ICJ to require detention until all of G.W.'s juvenile matters in the District were resolved or until Virginia took custody or consented to his release.G.W. filed a petition for a writ of habeas corpus, arguing that DYRS had no authority under the ICJ to detain him once Virginia failed to take custody. DYRS opposed the petition, citing ICJ rules and an advisory opinion by the Interstate Commission for Juveniles. The Superior Court of the District of Columbia denied the petition, relying on the advisory opinion that interpreted the ICJ rules to require detention until charges in the holding state were resolved or there was consent from the demanding state.The District of Columbia Court of Appeals reviewed the case. Since the trial court's ruling, the Commission withdrew the advisory opinion, and both the Commission and the District of Columbia conceded that the ICJ rules did not require G.W.'s detention. The Court of Appeals agreed, holding that ICJ Rule 7-103 did not address detention and that ICJ Rule 6-102.2 required detention only until the demanding state returned the juvenile or the time period for doing so expired. Consequently, the Court of Appeals reversed the judgment of the Superior Court. View "In re G.W." on Justia Law

T.B., a juvenile, was adjudged delinquent by the Superior Court of the District of Columbia for carrying a pistol without a license and possessing unregistered ammunition. The case arose from two Instagram live videos observed by Officer Moore of the Metropolitan Police Department. In the first video, T.B. was seen displaying a black Glock-style handgun. In the second video, T.B. was seen with a light-colored object in his waistband, which officers believed to be a firearm. When officers arrived at the scene, they found a tan-gold-colored pistol on the ground near where T.B. had been standing.The Superior Court incorporated Officer Moore’s testimony from a suppression hearing into the trial. Officer Moore testified about the events leading to T.B.'s arrest and the officers' observations from the Instagram videos. Officer Laielli also testified, describing T.B.'s behavior in the second video as characteristic of an armed gunman. The court found the evidence sufficient to prove beyond a reasonable doubt that T.B. possessed the tan-gold-colored pistol and committed him to the Department of Youth Rehabilitation Services for up to one year.On appeal, T.B. argued that the evidence was insufficient to support the court’s findings and that the trial court erred in admitting the officers’ testimony. The District of Columbia Court of Appeals reviewed the case and found that the evidence, including the Instagram videos and the officers’ observations, was sufficient to support the trial court’s findings. The appellate court also concluded that any error in admitting the officers’ testimony was harmless, as the trial court’s findings were based on its own viewing of the video evidence. The Court of Appeals affirmed the judgment of delinquency. View "In re T.B." on Justia Law

G.W. was convicted of simple assault in 2019 after allegedly grabbing the jacket of a Metropolitan Transit Police Department officer outside the Anacostia Metro Station. G.W. filed a notice of appeal, and the case was remanded to allow the trial court to set aside his conviction under the Youth Rehabilitation Act (YRA). Following the trial court's set-aside order and issuance of a new judgment and commitment order, G.W. filed a new notice of appeal, challenging his conviction.The Superior Court of the District of Columbia initially convicted G.W. of simple assault. G.W. timely filed a notice of appeal, and the case was stayed pending the outcome of the en banc decision in Perez Hernandez v. United States, which addressed the elements of an offensive touching assault. After the decision in Perez Hernandez, the stay was lifted, and G.W. sought an indicative ruling for a YRA set-aside. The trial court issued an indicative set-aside order, and the case was remanded. The trial court then issued a set-aside order and an amended judgment and commitment order, which G.W. appealed.The District of Columbia Court of Appeals reviewed the case and concluded that G.W.'s appeal was properly before the court. The court determined that the trial court had not applied the correct elements of an offensive touching assault as defined in Perez Hernandez. Specifically, the trial court did not consider whether G.W.'s actions would offend a person's reasonable sense of personal dignity and whether G.W. acted with the purpose of causing offense or knowing that his actions would cause offense. The court vacated the judgment and remanded the case for the trial court to make the necessary findings regarding G.W.'s mens rea and the nature of the touch. The court did not reach G.W.'s Rule 16 claim due to the decision to remand. View "G.W. v. United States" on Justia Law