Justia Juvenile Law Opinion Summaries

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

Fifteen-year-old Lucas Orozco was charged with robbery and burglary, both felonies, for allegedly robbing a convenience store. After a magistrate court determined there was probable cause to charge Orozco with the felonies, it waived juvenile jurisdiction and bound him over to district court as an adult pursuant to Idaho Code section 20-509. Orozco objected to this automatic waiver, filing a motion with the district court challenging the constitutionality of section 20-509. The district court denied the motion, relying on precedent from the Idaho Court of Appeals, which previously upheld the constitutionality of section 20-509. Orozco appealed, arguing that the automatic waiver denied him procedural due process protections afforded to him by the U.S. Constitution. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Orozco" on Justia Law

John Doe was a minor at the time the State alleged he committed two counts of lewd and lascivious conduct against a minor under the age of sixteen. Doe maintained his innocence, but argued that even if he did commit the acts alleged, the petition was time-barred under the four-year, catch-all limitation for civil actions found in Idaho Code section 5-224. The magistrate court (“juvenile court”) denied Doe's motion to dismiss the petition as untimely, and thereafter granted the State’s motion to waive Doe into adult proceedings. On intermediate appeal, the district court affirmed the decision of the juvenile court. The issue presented for the Idaho Supreme Court's review was whether proceedings under the Juvenile Corrections Act ("JCA") were "civil actions" subject to a civil statute of limitations. The Court concluded they were not, and affirmed the juvenile court, finding at JCA petition was not subject to the limitation in Idaho Code 5-224. View "Idaho v. Doe" on Justia Law

James Hairston was sentenced to death after a jury convicted him of two counts of first-degree murder in connection with the deaths of William and Dalma Fuhriman. Hairston was about nineteen and a half when he killed the Fuhrimans. In this, his fourth post-conviction petition, Hairston argued his sentence was unconstitutional because: (1) he was under the age of twenty-one at the time of the offense; and (2) the trial court failed to give adequate consideration to the mitigating factors that had to be considered with youthful defendants. The district court dismissed Hairston’s first claim after holding that he failed to show that evolving standards of decency prohibited imposing the death penalty for offenders between the ages of eighteen and twenty-one. The court dismissed Hairston’s second claim after finding that there was no basis to extend the special sentencing considerations that have been specifically limited to juvenile defendants under eighteen to those under twenty-one. Finding no reversible error in those judgments, the Idaho Supreme Court affirmed. View "Hairston v. Idaho" on Justia Law

Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law

Relying on Idaho Criminal Rule 47, Jane Doe filed a motion to modify disposition requesting that the juvenile court place her back on probation after sentence had been imposed, and modify its previous computation of credit for time served. The juvenile court held that Doe’s motion was actually a motion to reduce sentence under Idaho Criminal Rule 35 (a rule which has not been incorporated into the Idaho Juvenile Rules) and concluded that it did not have jurisdiction to consider Doe’s motion. Doe appealed the juvenile court’s decision to the district court. The district court affirmed the decision, holding that Rule 47 did not grant jurisdiction to reduce the sentence, but that jurisdiction existed under Idaho Code sections 20-505 and 20-507. The district court held that whether the sentence should be modified was a discretionary call and that the juvenile court did not abuse its discretion in declining to place Doe back on probation or incorrectly calculate Doe’s credit for time served. The Idaho Supreme Court agreed with the district court’s decision to affirm the magistrate court’s denial of Doe’s motion to modify disposition, but took the opportunity to explain there was no jurisdiction for the juvenile court to modify the juvenile’s sentence once it had been imposed and the time for appeal had run. View "Idaho v. Jane Doe (Juvenile)" on Justia Law

In 2009, the State filed a petition against John Doe, charging that he was within the purview of Idaho's Juvenile Corrections Act (JCA) for delivery of a schedule III controlled substance, hydrocodone. The State and Doe's counsel reached an agreement whereby Doe admitted to the charge and, in exchange, the State waived proceedings to bring Doe into adult court. At the conclusion of Doe's sentencing hearing, the magistrate judge memorialized his ruling in a "decree" that was issued that same day. The decree stated, "It is hereby Ordered, Adjudged and Decreed that [Doe] is within the purview of the [JCA] and shall be placed on Formal Probation supervision not to exceed 2 years." In the first year of Doe's probation, he had two probation review hearings, both of which demonstrated good behavior. At Doe's one-year probation review hearing, Doe's counsel argued that the magistrate should convert his formal probation to an informal adjustment. Doe's counsel could not cite any authority for converting the sentence, but believed that the court had broad authority to do so based on the interests of justice. The State objected and argued that the court did not have authority to convert the formal probation to an informal adjustment. Ultimately, the magistrate court stated that it had the authority to convert the sentence and entered a "supplemental decree nunc pro tunc to date of original order," granting Doe an informal adjustment and dismissing the case. The magistrate then issued an Order Supplementing Decree that provided "Formal Probation converted to Informal Adjustment, nunc pro tunc 05/05/09." The State filed an appeal to the district court. The district court affirmed the magistrate court's order. The State timely appealed to the Supreme Court. Because it was improper for the magistrate to convert Doe's sentence, any subsequent dismissal or termination of the improperly substituted informal adjustment could not be upheld. The Supreme Court reversed the district court's order and remanded the case for reinstatement of the 2009 decree. View "Idaho v. Doe (2012-09)" on Justia Law