Justia Juvenile Law Opinion Summaries

In 2013 while he was in custody, investigators questioned a then- 18-year-old Tyler Estrada abut a Gwinnett County homicide. Estrada had been in custody in DeKalb County. At an evidentiary hearing, audio recordings of Estrada’s custodial statement were placed into evidence, the trial court determined that though Estrada invoked his right to counsel, he never waived his Miranda rights either in writing or verbally. Accordingly, the trial court granted Estrada’s motion to suppress the statement. The State appealed. Finding no reversible error to that suppression order, the Supreme Court affirmed. View "Georgia v. Estrada" on Justia Law

The People filed a petition under Welfare and Institutions Code section 602, alleging that Carlos H. committed two counts of sexual battery against a female high school classmate. Prior to adjudication, the juvenile court issued a restraining order against Carlos prohibiting him from, among other things, contacting the victim through a third party, and directing him to stay 100 yards away from the victim. The court was unpersuaded by the premise inherent in Carlos’s argument that the Legislature intended that persons threatened by a minor should enjoy less protection than persons threatening the minor. The court held that the order form used by the juvenile court to enter the order, including the "other orders" in section 9 of the form, was a reasoned and reasonable response by the juvenile court to Carlos’s conduct and the other relevant facts of the case (e.g., the fact that Carlos and the victim no longer attend the same school). The court also concluded that the order was entirely consistent with the public policy objectives underlying the juvenile delinquency laws generally and section 213.5 specifically. Accordingly, the court affirmed the order because the juvenile court’s decision was not arbitrary, capricious or patently absurd. View "In re Carlos H." on Justia Law

Contra Costa County Children and Family Services filed petitions concerning P.W., then 12 years old, and his sister, M.W., 11, alleging Mother caused P.W. serious physical harm during an altercation and her untreated mental condition impaired her ability to adequately parent. The children reported that they did not feel safe. Family members and close friends reported concern for the children’s well-being and had asked Mother to seek treatment, suspecting she might be bipolar. The children were placed in foster homes. Mother was granted supervised visitation. The disposition report advised that Mother had several previous dependency cases since 1994. Her parental rights to two other children had been terminated. There was an earlier dependency case involving P.W. and M.W., which concluded in reunification. Mother did not appear at a continued permanency review hearing 18 months later. The court found that returning the children to Mother’s custody would create a substantial risk of detriment to the children’s safety and physical or emotional well-being, remarking this was “not even a close call.” It found Mother had been offered reasonable reunification services and declined to continue the matter, noting that the children still feared Mother and opposed visitation. The court scheduled a hearing for terminating Mother’s reunification services. The court of appeal declined Mother’s petition to set aside the order scheduling that hearing. View "N.M. v. Superior Court" on Justia Law

Calvin S. was declared a ward of the court under Welfare and Institutions Code section 602 and committed to the DJF for a maximum term of 15 years four months after he committed assault with a firearm and assault with intent to commit a sexual offense. The court concluded that the juvenile court abused its discretion in committing Calvin to the DJF rather than letting him remain in juvenile hall. The court also concluded that the juvenile court should have stayed the term imposed for assault with intent to commit a sexual offense under Penal Code section 654. Accordingly, the court reversed the commitment order and remanded for a new disposition hearing. The juvenile court is directed to stay execution of any term of confinement imposed on the sustained allegation of assault with intent to commit a sexual offense. View "In re Calvin S." on Justia Law

Petitioner was sentenced to life imprisonment without parole for a nonhomicide offense he committed at the age of sixteen. After Graham v. Florida was decided, petitioner sought postconviction relief but the state courts denied it. The court concluded that petitioner's state court adjudication constituted an unreasonable application of Graham where Virginia courts unreasonably ignored the plain language of the procedures governing review of petitions for geriatric release, which authorize the State Parole Board to deny geriatric release for any reason, without considering a juvenile offender’s maturity and rehabilitation. In light of the lack of governing standards, the court concluded that it was objectively unreasonable for the state courts to conclude that geriatric release affords petitioner with the “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” Graham demands. Accordingly, the court affirmed the district court's grant of habeas relief and remanded so that petitioner can be resentenced in accordance with Graham and the Eighth Amendment. View "LeBlanc v. Mathena" on Justia Law

The Los Angeles County District Attorney filed two wardship petitions, alleging that appellant, age 17, committed misdemeanor disorderly conduct by soliciting or agreeing to engage in prostitution on two different dates. Appellant moved under to exclude all evidence that she engaged in commercial sexual acts, because she was a “victim of human trafficking,” who had been coerced into performing those acts by a pimp who was a human trafficker under Penal Code 236.1(c).. The district attorney argued that neither petition alleged she had engaged in any commercial sex act. The court heard the testimony of two undercover police officers and of an expert on human trafficking and found appellant to have committed the charged acts “as a result of being a victim of human trafficking,” but denied her motion to exclude evidence. The court concluded that Evidence Code 1161 did not apply to juvenile proceedings and, even if it did, would not apply to cases in which the victim of human trafficking did not actually engage in “sexual conduct on account of which anything of value is given or received by any person.” The court of appeal reversed, reasoning that section 1161 does apply in juvenile proceedings, and that acceptance of the prosecutor’s interpretation of that statute would virtually wipe out a significant protection afforded victims of human trafficking. View "In re N.C." on Justia Law

At issue in these cases was what happens when the State fails to file a petition alleging delinquency against a juvenile who was not detained within 30 days of the filing of the complaint or seek an extension of that deadline from the juvenile court. In In the "Interest of M.D.H.," (779 SE2d 433 (2015)), a panel of the Court of Appeals held that the failure to comply with section 15-11-521(b) required dismissal of the juvenile case, but the dismissal was without prejudice. Three days later, in "Interest of D.V.H.," (779 SE2d 122 (2015)), a different panel answered the same question the opposite way, concluding that a violation of section 15-11-121(b) required dismissal with prejudice. The Supreme Court granted certiorari in both cases, asking whether the Court of Appeals correctly applied OCGA section 15-11-521 (b). The Supreme Court held that if the State fails to file a delinquency petition within the required 30 days or to seek and receive an extension of that deadline, the case must be dismissed without prejudice. Accordingly, the Court affirmed the Court of Appeals’ judgment in M.D.H., and reversed the judgment in D.V.H. View "In the Interest of M.D.H." on Justia Law

The State filed an amended petition seeking to adjudicate five children under Neb. Rev. Stat. 43-247(3)(a). At the beginning of the adjudication hearing, the State moved to dismiss without prejudice two factual allegations of the petition. The court dismissed the two allegations with prejudice. The State appealed. The Supreme Court affirmed the order as modified, holding that because the State sought dismissal of the factual allegations before any evidence was presented and before the children’s parents entered their admissions to certain counts, the juvenile court erred in ordering the dismissal to be with prejudice. View "In re Interest of Antonio J." on Justia Law

Juvenile defendant Trey M. challenged his three convictions for felony harassment under RCW 9A.46.020. The Court of Appeals certified the issue to the Washington Supreme Court of whether the United States Supreme Court's decision in "Elonis v. United States," (135 S. Ct. 2001 (2015)) had any impact on the Washington Court's "reasonable person standard" for what constituted a "true threat" under the First Amendment to the United States Constitution. The Washington Supreme Court held that because "Elonis" expressly avoided any First Amendment analysis, it provided no basis for the Court to abandon its established First Amendment precedent. Accordingly, the Court affirmed. View "Washington v. Trey M." on Justia Law

The victim and her boyfriend’s eight-year-old son exited a bus in San Leandro. The boy then informed the victim that he had seen “a male,” later identified as 16-year-old D.H., “standing behind her on the bus and exposing his penis and masturbat[ing]” and that “the male eventually ejaculated and the semen landed on the back of [the victim’s] clothing.” The victim had not noticed anything at the time but discovered “a white substance” on the back of her jacket. She eventually reported the incident. A juvenile court declared D.H. a ward of the court and placed him on probation after he admitted to a misdemeanor count of indecent exposure. Raising mostly constitutional claims of vagueness and overbreadth, he challenged four probation conditions that required him: not to access pornography; to submit to warrantless searches of his electronic devices and provide passwords; to attend school regularly; and not to leave home without a parent or the probation officer’s permission. The court of appeal held that the no-pornography and electronics search conditions were vague, and remanded. The court affirmed the attendance condition and, in light of ambiguity in the record, requested clarification of whether the court intended to impose the stay-home condition. View "In re D.H." on Justia Law