Justia Juvenile Law Opinion Summaries

A minor admitted to committing vandalism causing property damage exceeding $400. The juvenile court adjudged the minor a ward of the court, placed him on probation, and reserved jurisdiction over restitution. At a later hearing, the court accepted a stipulation between the minor and the prosecution regarding the amount of restitution and ordered the minor, his co-offender, and his parents jointly and severally liable for payment. The minor did not appeal the initial dispositional or restitution orders.Subsequently, after a statutory amendment to Welfare and Institutions Code section 730.6 eliminated joint and several liability for co-offenders in juvenile restitution, the minor requested that the court divide liability, making him responsible solely for half the restitution. The Superior Court of San Diego County denied this request, reaffirmed joint and several liability, and after the minor successfully completed probation, dismissed the petition and sealed his records. The minor appealed the postjudgment orders, arguing the new law should apply retroactively to his case because his case was not yet final.The California Court of Appeal, Fourth Appellate District, Division One, reviewed whether the case was final for purposes of retroactive application of ameliorative legislation under the Estrada rule. The court held that a juvenile case becomes final for these purposes when the dispositional order is not appealed within the allowed time and direct review is exhausted. The court found that the minor’s case became final before the new statute took effect because he did not appeal the dispositional or restitution orders. As a result, the amendment did not apply retroactively to his case. The court affirmed the postjudgment orders. View "In re Christian V." on Justia Law

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

A child was removed from the care of their mother in Utah after the mother experienced a mental health crisis, leading to the Utah Division of Child and Family Services (DCFS) taking protective custody of the child. The father, living in Georgia, sought custody. The juvenile court ordered DCFS to request a home study from Georgia officials via the Interstate Compact on the Placement of Children (ICPC). Georgia attempted to conduct the home visit twice, but was unable to complete it because the father lacked a stable residence. The court found the child could not safely be returned to the father and ultimately terminated his parental rights.The Second District Juvenile Court in Weber County initially adjudicated the child dependent as to the mother and neglected as to the father due to abandonment, later revising the finding to dependency after the father argued he had been denied access by the mother. Despite the father's efforts to establish paternity and seek visitation, the court maintained the child in DCFS custody with a goal of reunification. After two failed ICPC home studies due to the father's unstable housing, the court changed the permanency goal to adoption and terminated reunification services. DCFS then filed to terminate the father’s parental rights, and after trial, the juvenile court issued an order terminating those rights.The Supreme Court of the State of Utah reviewed the case on certification from the Utah Court of Appeals. The father argued that his appointed counsel was ineffective for not objecting to the use of the ICPC process or proposing alternatives for the required home visit. The Supreme Court held that counsel’s performance was not objectively unreasonable under the Strickland standard, noting that the ICPC was commonly used in these circumstances and alternatives were impractical or unlikely to be accepted. The court affirmed the termination of the father’s parental rights. View "In re B.G." on Justia Law

A defendant, who was seventeen years old at the time, participated in a premeditated and armed home invasion along with several accomplices. The group entered the victim’s home with knives and a handgun, threatened the victim, and inflicted physical injury by striking him with a shotgun. Prior to this incident, the defendant had a history of escalating criminal behavior, including multiple arrests and Family Court appearances since age thirteen. He had received Family Court services for about five years, including supervision and therapy for several diagnosed mental health conditions.Following indictment on charges of first-degree burglary and first-degree robbery, the People moved to prevent the case’s transfer from the youth part of County Court to Family Court, citing “extraordinary circumstances.” The youth part convened a hearing, considered the defendant’s history of receiving Family Court services, and determined, after weighing aggravating and mitigating factors, that extraordinary circumstances existed warranting retention of the case in the youth part. The defendant was subsequently convicted after a jury trial and sentenced to a state prison term.The Appellate Division affirmed, finding that the violent nature of the offense, the defendant’s lack of positive response to prior Family Court services, and his continued escalated criminal activity supported the youth part’s determination. One Justice dissented, arguing for a stricter interpretation of “extraordinary circumstances,” but leave to appeal was granted.The New York State Court of Appeals reviewed whether the youth part abused its discretion in denying removal to Family Court. The Court held that the youth part did not abuse its discretion as a matter of law, emphasizing the broad judicial discretion provided by the legislature in determining extraordinary circumstances under the Raise the Age statute. The order of the Appellate Division was affirmed. View "People v Guerrero" on Justia Law

Two children were removed from their parents’ home in June 2020 and subsequently found by the Juvenile Court of Williams County, North Dakota, to be children in need of protection. The children remained in the custody of North Star Human Service Zone. In 2022, the State petitioned to terminate the parental rights of both parents, but those petitions were denied. On April 1, 2025, the State filed new petitions to terminate parental rights. Following a hearing, the juvenile court found that termination was in the children’s best interests and ordered that the parental rights of G.G. (the father) and S.F. (the mother) be terminated. The court issued oral and written findings supporting its decision, but neither addressed whether the Indian Child Welfare Act (ICWA) applied. G.G. appealed the termination of his parental rights, contending that the juvenile court’s findings were inadequate because they failed to determine whether ICWA applied. The State responded that ICWA was not applicable. The Supreme Court of North Dakota noted that in termination proceedings, a juvenile court must make a threshold inquiry and finding as to whether ICWA applies whenever there is reason to know the child may be an Indian child. The Supreme Court further explained that this inquiry is required for each new petition, and the absence of such a finding constitutes clear error. The Supreme Court of North Dakota held that the juvenile court’s failure to make a threshold finding on ICWA applicability was clearly erroneous. The Supreme Court remanded the case to the juvenile court with instructions to make a finding on whether ICWA applies, based on the existing record or with additional evidence if necessary. The Supreme Court retained jurisdiction during the remand. View "Interest of D.G." on Justia Law

A young child was removed from her mother’s care, along with her two siblings, due to concerns of neglect and abuse. After initial placement with their maternal grandmother, the grandmother asked for the children to be removed, and the subject child was subsequently placed with a licensed foster parent, J.D., where she remained. The child’s brother was later hospitalized and, upon discharge, was placed with the grandmother, while the subject child remained with J.D. Over the course of the proceedings, professional testimony described the child’s attachment disorder, trauma history, and the risks posed by placement changes. Reports also indicated the child was thriving in her current placement and that sibling reunification was not in her best interest due to safety and emotional concerns.The Fourth Judicial District Court, Missoula County, held multiple hearings regarding placement and permanency. After terminating parental rights and granting permanent legal custody to the Montana Department of Public Health and Human Services, the court denied the grandmother’s request for placement, finding good cause to depart from statutory placement preferences based on the child’s extraordinary mental and emotional needs. The court incorporated findings from previous orders, relied on professional testimony and a report from the Court Appointed Special Advocate, and approved adoption by J.D. as the permanency plan.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in approving adoption as the permanency plan and denying the grandmother’s placement request. The Supreme Court held that, despite some imprecise language, the District Court applied the correct statutory standards, made sufficient findings regarding the child’s best interests, and did not abuse its discretion. The Supreme Court affirmed the District Court’s order. View "In re M.L.O.-L." on Justia Law

The case concerns a father and mother with four minor children. Dependency jurisdiction was initially asserted over the children due to the father’s alcohol abuse and the mother’s failure to protect the children. After the parents entered into a stipulation, restrictions on the father’s visitation were removed, and joint custody was restored. However, a subsequent domestic violence incident involving the father led to a new dependency petition. The father was accused of slapping the mother while possibly intoxicated, which was witnessed by the eldest child. The investigation also revealed prior domestic violence calls. As a result, the children were detained from the father and released to the mother, with the father granted monitored visitation.The Superior Court of Los Angeles County sustained allegations against the father for domestic violence and alcohol abuse, declared the children dependents, and removed them from the father’s custody. The mother was given family preservation services, while the father received enhancement services and monitored visitation. At a six-month review hearing, it was reported that the father completed a substance abuse program but continued to engage in concerning behavior, including leaving threatening voicemails, appearing intoxicated, and being physically aggressive toward the mother. The mother obtained a restraining order, and the Department of Children and Family Services recommended terminating jurisdiction with sole custody to the mother and monitored visitation for the father.The California Court of Appeal, Second Appellate District, Division Eight, reviewed whether the lower court erred in requiring the father to pay for a professional visitation monitor as a condition of visitation without considering his ability to pay or reasonable alternatives. The appellate court held that the juvenile court abused its discretion by not inquiring into the father’s financial ability or considering alternatives such as an unpaid monitor. The order requiring the father to pay for a professional monitor was reversed and remanded for further proceedings; the custody order was otherwise affirmed. View "In re Reyna R." on Justia Law

A 16-year-old juvenile was charged with serious offenses, including first degree sexual assault, terroristic threats, assault by strangulation or suffocation, and third degree domestic assault, all stemming from two incidents involving his then-girlfriend. After an investigation initiated by a friend's report, law enforcement gathered police reports, photographs, text message screenshots, and a video interview of the alleged victim. The State moved to transfer the juvenile’s case from the juvenile court to the adult docket of the county court.At the transfer hearing in the County Court for Buffalo County, the State did not call any witnesses and instead offered documentary and video exhibits without authentication or supporting testimony. The juvenile’s counsel objected on due process, foundation, and confrontation grounds, arguing he could not cross-examine or otherwise challenge the evidence. The court overruled the objections, received the evidence, and concluded that most statutory factors favored transfer, despite finding some factors supported retention in juvenile court. The court found the State met its burden by a preponderance of the evidence and ordered the case transferred.The Nebraska Court of Appeals, in a split decision, affirmed the juvenile court’s actions. The majority held that the juvenile’s due process rights were satisfied because he had a hearing, representation by counsel, and a specific written decision, relying on the standards set forth in Kent v. United States. The dissent disagreed, arguing the lack of authentication and sponsoring witnesses for the State’s exhibits deprived the juvenile of due process.The Nebraska Supreme Court reviewed the case and affirmed the Court of Appeals’ decision. The Supreme Court held that the juvenile’s due process rights were not violated under these facts, as counsel had access to the State’s evidence and an opportunity to respond, and the evidence bore sufficient indicia of reliability. The Court also concluded that the juvenile court did not abuse its discretion in ordering the transfer to adult court. View "In re Interest of Aaden S." on Justia Law

A juvenile was arrested at age twelve for the murder and aggravated robbery of a convenience store clerk. Surveillance video showed the juvenile entering the store multiple times, stealing items, and ultimately shooting the victim eight times. After the murder, he calmly stole additional items and discarded evidence. The juvenile confessed to the crimes and exhibited a history of violent and antisocial behavior, documented by family members, school officials, therapists, and juvenile detention staff. Multiple psychological evaluations were conducted, yielding conflicting diagnoses of autism, conduct disorder, and schizophrenia, but all agreed he knew right from wrong.The juvenile division of the Miller County Circuit Court designated him as an extended juvenile jurisdiction (EJJ) offender. He was adjudicated delinquent by a jury, committed to the Arkansas Division of Youth Services (DYS), and the imposition of an adult sentence was suspended pending further review. The Arkansas Court of Appeals affirmed these rulings. Over several years, DYS provided rehabilitative services. After several petitions concerning release and adult sentencing, the State filed a petition to impose an adult sentence as the juvenile approached age twenty, citing ongoing concerns about rehabilitation and public safety. At the subsequent hearing, DYS staff testified that the juvenile had made progress and completed treatment goals, but the State introduced evidence of recent violent incidents and inconsistencies in staff testimony.The Supreme Court of Arkansas reviewed the circuit court’s order imposing an adult sentence, applying a clearly erroneous standard. The court affirmed the circuit court’s findings that the juvenile was not amenable to treatment and that public safety required the imposition of an adult sentence. The court held that the circuit court’s assessment of the statutory factors and credibility determinations were not clearly erroneous, and affirmed the life sentence with the possibility of parole after thirty years. View "MERRELL v. STATE OF ARKANSAS" on Justia Law

Four juveniles conspired to rob a victim of vaping products in Colorado in 2019. During the incident, one of the juveniles, who is Black, shot and killed the victim. All four were initially charged with felony murder, aggravated robbery, and conspiracy to commit aggravated robbery. Subsequent investigation revealed that the shooter acted alone in confronting and shooting the victim, while the other three, including two non-Black juveniles, had more limited roles and cooperated with law enforcement. The two non-Black juveniles received plea deals allowing them to be tried in juvenile court and were sentenced to two years in the Division of Youth Services, while the two Black defendants, including the shooter, were prosecuted in district court and faced substantially harsher potential sentences.The District Court for Arapahoe County denied the shooter's motion to dismiss for selective prosecution, finding that he was not similarly situated to his non-Black codefendants due to his greater culpability as the shooter. The court also found that statistical evidence provided did not establish discriminatory purpose by the prosecution. The case proceeded to trial, and a jury convicted the shooter, who was sentenced to life in prison with the possibility of parole after forty years. On appeal, the Colorado Court of Appeals affirmed the trial court’s denial of the motion to dismiss, agreeing that the shooter was not similarly situated to the other defendants. The appellate division did not address whether the statistical evidence sufficed to show discriminatory purpose.The Supreme Court of Colorado affirmed the judgment of the Court of Appeals. It held that the defendant failed to establish a claim of selective prosecution because he did not show a discriminatory effect or purpose. Specifically, he was not similarly situated to his non-Black codefendants, and his statistical evidence did not demonstrate that similarly situated non-Black individuals were treated differently. View "Mitchell v. People" on Justia Law