Justia Juvenile Law Opinion Summaries

Ramiro Munoz, a member of a criminal street gang, was convicted in 2008 of first-degree murder and shooting at an occupied motor vehicle, with firearm and gang allegations found true. Munoz, who was 15 years old at the time of the crime, was sentenced to 50 years to life in prison. In 2023, Munoz filed a petition for recall and resentencing under Penal Code section 1170, subdivision (d)(1), arguing that his sentence was the functional equivalent of life without the possibility of parole, making him eligible for relief under the statute.The Superior Court of Los Angeles County denied Munoz's petition, stating that he would be eligible for parole under section 3051 in 2029, when he would be 39 years old. Munoz appealed the decision, and the case was reviewed by the Court of Appeal of the State of California, Second Appellate District, Division Seven.The Court of Appeal affirmed the superior court's decision, holding that Munoz's sentence of 50 years to life is not the functional equivalent of life without the possibility of parole. The court concluded that section 1170, subdivision (d)(1), applies only to juvenile offenders explicitly sentenced to life without the possibility of parole and does not extend to those with lengthy sentences that may be considered de facto life without parole. The court also noted that Munoz would have a realistic opportunity to obtain release from prison during his expected lifetime, distinguishing his case from others with significantly longer sentences. View "People v. Munoz" on Justia Law

Cynthia Maldonado and Martha Amaro, who lived on both sides of the Oklahoma-Kansas border and in Mexico, appealed a trial court's order that Oklahoma had jurisdiction over a juvenile deprived proceeding under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The trial court found that Maldonado's child, L.A., had resided in Oklahoma for six months preceding the commencement of the proceeding, making Oklahoma the child's home state. The court also adjudicated the children deprived as to Maldonado.The Texas County District Court of Oklahoma ordered that N.A. and L.A. be taken into emergency custody by the Oklahoma Department of Human Services (OKDHS) after Maldonado and N.A. tested positive for methamphetamine at birth. Maldonado filed a motion arguing that Oklahoma did not have jurisdiction under the UCCJEA, claiming that Mexico and Kansas were the children's home states. The State argued that Oklahoma had jurisdiction under the Oklahoma Children's Code. The trial court found that L.A. had lived in Oklahoma for six months before the proceeding and adjudicated the children deprived.The Supreme Court of the State of Oklahoma reviewed the case and affirmed the trial court's findings. The court held that the Oklahoma district court had subject matter jurisdiction over the juvenile deprived proceeding and that the UCCJEA applied to such proceedings. The court found that the trial court's determination that L.A. had resided in Oklahoma for six months preceding the proceeding was not clearly erroneous. The court also affirmed the trial court's order adjudicating the children deprived as to Maldonado, finding competent evidence to support the order. The appeal was not considered moot due to ongoing collateral consequences. View "IN RE: N.A.; STATE OF OKLAHOMA vs MALDONADO" on Justia Law

E.M., a fifteen-year-old, was arrested for allegedly killing S.A. and wounding four others in a racially motivated drive-by shooting. The State charged E.M. with multiple felonies, including murder, in juvenile court and sought to transfer the case to district court.The juvenile court held a preliminary hearing where eight witnesses testified. The court found probable cause that E.M. was a principal actor in the murder and analyzed whether retaining jurisdiction was contrary to the best interests of E.M. and the public. The court considered the seriousness of the crime, the aggressive and premeditated nature of the offense, E.M.'s traumatic background, lack of prior criminal record, and the likelihood of rehabilitation. The court noted E.M.'s difficult childhood, marked by extreme trauma, and his progress in detention but also highlighted incidents of racially motivated violence. Ultimately, the court concluded that transferring E.M. to district court was appropriate.The Utah Supreme Court reviewed whether the juvenile court abused its discretion in transferring E.M.'s case. The court emphasized that the Transfer Statute requires a holistic approach, considering all relevant circumstances surrounding the qualifying offense. The court found that the juvenile court appropriately considered the context of the crime, including non-qualifying offenses, to assess the seriousness and premeditated nature of the offense. The court also held that the juvenile court did not err in weighing E.M.'s trauma history as a factor that could impact the likelihood of rehabilitation.The Utah Supreme Court upheld the juvenile court's decision, finding no abuse of discretion in the transfer of E.M.'s case to district court, concluding that it was in the best interests of both E.M. and the public. View "In re E.M." on Justia Law

In this case, the State charged an adult with capital murder, alleging he was sixteen at the time of the offense. The juvenile court found it was not practicable to proceed before the adult turned eighteen because the State lacked probable cause to arrest him at that time. The court of appeals reversed and dismissed the case, holding that probable cause existed to arrest him before he turned eighteen, thus the State failed to establish it was impracticable to proceed.The juvenile court granted the State’s motion to transfer the case to adult criminal court, combining elements of two statutory good cause alternatives. The court of appeals vacated the order and dismissed the case for want of jurisdiction, noting the juvenile court’s findings were difficult to decipher and lacked a “due diligence” finding required by one of the statutory alternatives. The court of appeals concluded that the State had sufficient evidence to establish probable cause before the respondent turned eighteen, and the reasons for delay were not beyond the State’s control.The Supreme Court of Texas reviewed the case and largely agreed with the dissenting justice from the court of appeals. The Court held that the development of probable cause alone does not determine whether it is “practicable to proceed” with a juvenile prosecution before a person reaches adulthood. Other reasons beyond the control of the State may support such a finding. The Court found that the juvenile court erred in conflating “practicable to proceed” with the existence of probable cause and remanded the case to the juvenile court for a new transfer hearing. The Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with its opinion. View "IN THE MATTER OF J.J.T." on Justia Law

In March 2023, J.D. was involved in two separate incidents at the Pacific View Mall. In the first incident, J.D. stole a cell phone from Mia M. while she was sitting with friends. Later that day, J.D. and three others attacked Priscilla E., taking her cell phone and assaulting her. Both incidents were captured on mall surveillance, and the victims identified J.D. as the perpetrator.The Ventura County District Attorney's office filed a juvenile petition in July 2023, charging J.D. with the theft of Mia's cell phone. J.D. admitted to the theft in February 2024 and was placed on probation. In March 2024, a subsequent petition was filed, charging J.D. with felony assault for the attack on Priscilla. J.D. filed a motion to dismiss the felony assault charge, arguing that the prosecution should have been aware of both offenses and that they should have been prosecuted together.The trial court denied the motion to dismiss, finding that the two incidents were separate and distinct, occurring at different times and locations. The court determined that the evidence needed to prove the assault on Priscilla did not overlap significantly with the evidence needed to prove the theft from Mia.The California Court of Appeal, Second Appellate District, reviewed the case and affirmed the trial court's decision. The court held that the offenses were not part of a singular transaction and that the prosecution was not required to join the charges in a single proceeding. The court found no significant overlap in the evidence and concluded that the Kellett rule did not apply, as the incidents were distinct in time, location, and nature. The judgment denying the motion to dismiss was affirmed. View "In re J.D." on Justia Law

The case involves a seventeen-year-old named M.Z., who was adjudicated as a child in need of assistance (CINA) by the Circuit Court for Baltimore County due to behavioral issues and her mother's inability to manage her. M.Z. was placed in a therapeutic youth group home and later returned to her mother's custody. The Baltimore County Department of Social Services sought to terminate the CINA case, but M.Z.'s mother objected, citing ongoing behavioral concerns and the need for additional services.The Circuit Court for Baltimore County terminated the CINA case over the mother's objection, finding that the mother could adequately care for M.Z. and that the Department had exhausted its services. The mother appealed to the Appellate Court of Maryland, which dismissed the appeal, holding that the mother was not "aggrieved" by the termination since her custodial rights were restored.The Supreme Court of Maryland reviewed the case to determine whether a parent is entitled to appeal the termination of a CINA case over their objection. The court held that a parent is an "aggrieved party" entitled to appeal if they have not obtained the full relief sought in the juvenile court. The court emphasized that the CINA statute's purpose extends beyond parental rights to include the child's safety and well-being. The court found that the mother's interest in ensuring M.Z.'s safety and receiving necessary services was sufficient to make her an aggrieved party.The Supreme Court of Maryland reversed the judgment of the Appellate Court of Maryland and remanded the case for further proceedings to resolve the merits of the mother's appeal. View "In re M.Z." on Justia Law

The defendant, a seventeen-year-old, was convicted of the abduction and murder of eighty-nine-year-old Elleze Kennedy. Along with his co-defendants, the defendant followed Ms. Kennedy home, assaulted her, and placed her in the trunk of her car. They later set the car on fire, resulting in Ms. Kennedy's death from carbon monoxide poisoning. The defendant was sentenced to life in prison without parole.The Superior Court of Onslow County initially sentenced the defendant to life without parole. The Court of Appeals upheld this sentence, finding no error. The defendant then filed a motion for appropriate relief, arguing that his sentence was unconstitutional under Miller v. Alabama, which requires consideration of a juvenile's age and potential for rehabilitation before imposing a life without parole sentence. The Superior Court held a resentencing hearing and reaffirmed the life without parole sentence, considering the Miller factors.The Supreme Court of North Carolina reviewed the case. The court held that the defendant's J.E.B. claim, alleging gender bias in jury selection, was procedurally barred because it was not raised at trial or on direct appeal. The court also affirmed the lower court's decision to sentence the defendant to life without parole, finding that the sentencing court properly considered the Miller factors, including the defendant's age, immaturity, ability to appreciate risks, prior record, mental health, and potential for rehabilitation. The court concluded that the sentencing court did not abuse its discretion in weighing these factors and that the sentence did not violate the Eighth Amendment. The decision of the Court of Appeals was affirmed. View "State v. Sims" on Justia Law

In this case, the Alameda County Social Services Agency removed an eight-year-old girl, L., from her mother, L.W., after the mother was hospitalized due to a mental health crisis. L. had been living with her mother, stepfather, maternal grandmother, and siblings. The family had recently moved to a homeless shelter. When the mother left the shelter and did not return, the shelter called the police, and L. was taken into protective custody. The mother later contacted the Agency, explaining she had a mental health breakdown and was hospitalized. She had bipolar disorder and schizophrenia but had resumed taking her medication and was receiving psychiatric care.The juvenile court found that the mother’s mental health issues and the lack of a safe caregiver justified dependency jurisdiction under Welfare and Institutions Code section 300, subdivisions (b)(1) and (g). The court ordered L. to be placed with her biological father and terminated dependency jurisdiction. The mother appealed, arguing that the evidence did not support the court’s findings.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The court found no evidence that L. was left without a safe caregiver, as she was with her grandmother at the shelter. The court also found that the mother’s mental health was stable, and she was receiving treatment. There was no substantial evidence that the mother’s mental illness or purported substance abuse placed L. at substantial risk of physical harm or illness. The court concluded that the juvenile court erred in exercising jurisdiction under section 300, subdivisions (b)(1) and (g).The Court of Appeal reversed the juvenile court’s jurisdictional order and vacated the disposition order and all subsequent orders as moot. View "In re L.W." on Justia Law

A mother (TH) appeals a juvenile court's decision to change the permanency plan for her minor child (LH) from reunification to adoption. LH was taken into state custody shortly after birth due to both mother and child testing positive for opiates. The mother has another child, RH, who remained in her custody. The mother argues that the juvenile court did not consider LH's relationship with RH and that it abused its discretion by changing the plan to adoption despite her maintaining sobriety for six months.The District Court of Park County initially placed LH in the custody of the Department of Family Services (Department) and ordered the mother to abstain from controlled substances and undergo drug testing. Despite entering inpatient treatment and attending counseling, the mother continued to test positive for illegal substances, leading to suspended visitations with LH. The Department recommended changing the permanency plan to adoption after the mother failed to maintain sobriety and secure stable housing and employment.The Wyoming Supreme Court reviewed the case and found that the juvenile court did not abuse its discretion. The court noted that the juvenile court had ample evidence of LH's relationship with RH and the potential for sibling separation. The juvenile court's decision to change the permanency plan to adoption was based on the mother's failure to make sufficient progress on her case plan goals, particularly her sobriety and obtaining a stable living environment, within the statutory timeframe. The court emphasized that children have a right to stability and permanency, which outweighed the mother's progress in the months leading up to the permanency hearing.The Wyoming Supreme Court affirmed the juvenile court's decision to change the permanency plan from reunification to adoption, allowing the Department to cease reunification efforts. View "In re L.H. v. State" on Justia Law

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama. The district court denied his motion in 2016, and Mullins’s appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law