Justia Juvenile Law Opinion Summaries

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded. View "State v. Null" on Justia Law

The State filed a petition alleging that fifteen-year-old J.W.R. committed delinquent acts of incest. J.W.R. entered an Alford plea to the incest allegation. A juvenile court officer recommended J.W.R. be adjudicated a delinquent and placed in a residential treatment facility for sex offenders. The juvenile court issued a consent decree withholding adjudication that J.W.R. had committed a delinquent act. Over the State's objection, the court placed J.W.R. in the legal custody of juvenile court services, with the Department of Human Services as payment agent, for purposes of placement in a residential facility. The court of appeals sustained the State's writ of certiorari. The Supreme Court affirmed, holding that the legislature did not grant this authority to juvenile courts in Iowa Code 232.46. View "State v. Dist. Court" on Justia Law

Two petitions were filed alleging that fifteen-year-old A.K. was a delinquent child for committing three counts of sexual abuse in the second degree and four counts of assault with intent to commit sexual abuse involving three different children. After a hearing, the juvenile court adjudicated A.K. a delinquent on all seven counts. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the State proved beyond a reasonable doubt that A.K. committed three acts of sexual abuse in the second degree and three acts that would constitute assaults with intent to commit sexual abuse; but (2) the State did not meet its burden to prove A.K. committed one count of assault with intent to commit sexual abuse. View "In re A.K." on Justia Law

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible. View "State v. Pearson" on Justia Law