Justia Juvenile Law Opinion Summaries

Petitioner, convicted of murdering two teenage boys with intent to inflict torture, appealed the denial of his 28 U.S.C. 2254 petition for habeas relief. Petitioner committed the murders when he was 15 years old. Petitioner contends his counsel performed deficiently by failing to challenge the prosecution’s statements as either improper comments on petitioner's decision not to testify, in violation of Griffin v. California, or improper shifting of the burden of proof to the defense. The court concluded that, because there was no actual prosecutorial error, defense counsel’s decision to rebut the prosecution’s comments directly rather than object at trial or on appeal was adequate, and this strategy did not undermine the reliability of petitioner’s conviction. Petitioner also contends that his sentence violates the Eighth Amendment because it is the "functional equivalent" of a mandatory life-without-parole sentence, and he was a juvenile offender. The court concluded that there is a reasonable argument petitioner’s sentence is constitutional because it actually allows for the possibility of parole. Accordingly, the court affirmed the district court's judgment. View "Demirdjian v. Gipson" on Justia Law

In 1996, defendant Clifton Gibson was tried as an adult and convicted of first degree murder with special circumstances, assault with a firearm, and robbery. These offenses were committed when he was 17 years old, with two adult codefendants. Gibson was ultimately sentenced to life without possibility of parole (LWOP) for the murder, consecutive to a determinate term of 12 years, four months, in prison. In 2014, he filed a petition to recall his sentence pursuant to Penal Code section 1170, subdivision (d)(2), which was denied by the trial court on the ground he failed to demonstrate he had been rehabilitated or that he was remorseful. Defendant appealed. On appeal, defendant argued the trial court: (1) improperly limited applicability of section 1170, subdivision (d)(2) relief to juvenile defendants who did not actually kill the victim; (2) abused its discretion in denying the petition despite evidence to support the existence of all the statutory factors; and (3) “flouted Miller [v. Alabama, 132 S.Ct. 2455 (2012)] and Gutierrez[58 Cal.4th 1354 (2014)].” Finding no reversible error, the Court of Appeal affirmed. View "California v. Gibson" on Justia Law

What began as a fight between two students, C.W. and D.W., ended in the death of one of them. N.H., who was seventeen years old at the time, attended the fight to support his friend, D.W. N.H. allegedly grabbed a handgun from another individual and shot C.W. four times, including once in the back of the head. A video captured parts of the incident, and several witnesses made statements to the police that implicated N.H. N.H. also spoke to the police and said that he had shot only at the ground. At oral argument before the New Jersey Supreme Court, the State explained that it had not disclosed certain items in its possession which it did not intend to rely on at the waiver hearing. Those materials included additional witness statements, other police reports, and other videos of the event taken from different angles. N.H. moved for full discovery before the waiver hearing, and the trial court granted the request. The court analogized the filing of a juvenile complaint to the filing of a criminal indictment, which would trigger full discovery under Rule 3:13-3(b). The trial court stayed its order pending the outcome of the State's motion for leave to appeal. The Appellate Division affirmed the trial court's order. The issue raised by the State's appeal in this matter was whether a juvenile was entitled to full discovery when the State sought to waive jurisdiction and transfer a case from juvenile to adult court. The Supreme Court held the State is indeed required to disclose all discovery in its possession when it seeks to waive jurisdiction and transfer a case from juvenile to adult court. View "New Jersey in the Interest of N.H." on Justia Law

After his stepfather, Donald, assaulted his mother, Heidi, in Alexander’s presence, Alexander, then three years old, became the subject of a dependency petition. At the time, Donald, Alexander’s biological father, Joel, and Michael, the man with whom Heidi was living at the time of Alexander’s birth, had competing motions pending. Two weeks after the dependency petition was filed, the family court ruled that both Michael and Joel qualified as presumed parents and designated both under Family Code section 7612(c), which authorizes multiple presumed parents. Considering itself bound by that order, the juvenile court found both Michael and Joel to be presumed parents, but subsequently denied Michael visitation. The court found that Donald also satisfied the requirements for presumed parent status and designated him as such. The court of appeal held that the juvenile court erred in finding Michael to be a presumed parent. Because Welfare and Institutions Code section 316.2 grants exclusive jurisdiction over paternity issues to the juvenile court upon the filing of a dependency petition, the family court order on which the juvenile court relied, issued subsequent to the filing, was void. The court found no error in the designation of Donald as a presumed parent, which was supported by substantial evidence. View "In re Alexander P." on Justia Law

After two commitment hearings, the juvenile court entered an order committing Alan L. to the Office of Juvenile Services (OJS) for commitment at a youth rehabilitation and treatment center. In its first order, the court concluded that the State had not proved the necessary conditions for commitment, but the court subsequently found that the evidence supported a commitment order. Alan appealed, arguing (1) claim preclusion barred the State from presenting any new evidence at the second commitment hearing that was available to it before the first commitment hearing; and (2) the commitment hearing violated his right to due process because he could not confront and cross-examine individuals who provided adverse information against him. The Supreme Court affirmed, holding (1) Alan was not deprived of his right to procedural due process despite the State’s failure to comply with case law for seeking a new disposition or commitment to OJS; and (2) new evidence at the second commitment hearing, which became available after the first hearing, showed a change of circumstances warranting Alan’s commitment to OJS, and claim preclusion does not bar consideration of changed circumstances. View "In re Interest of Alan L." on Justia Law

Minor and his friends entered an Oakland home through a back window and took a watch, a camera, and loose change. They were apprehended blocks away. The dispositional report noted that Minor had a “difficult” relationship with his mother and admitted he had experimented with drugs and alcohol and had associated with members of the Norteños gang. Minor was in danger of failing most of his middle school classes. He had significant behavioral issue. The juvenile court placed Minor under the supervision of the probation department and imposed probation conditions, including a 6:00 p.m. curfew, a no-contact order as to the victim and Minor’s co-offenders, and requirements that Minor attend school, complete his school work, remain drug-free, submit to regular drug testing, and submit to a search of his person, residence, vehicles, containers, and “electronics, including passwords.” Minor unsuccessfully moved to delete the electronic search condition. The court stated that Minor “has some fairly substantial drug issues” and “we need to use the electronics to make sure we can monitor the purchase, or sales, usage [of drugs].” The court of appeal affirmed, holding that the condition was not overbroad, was reasonably related to potential future criminality, and was necessary to ensure compliance with other conditions. View "In re J.E." on Justia Law

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law

Sixteen-year-old M.H. used his smartphone to surreptitiously record a fellow high school student, Matthew B., in a school bathroom stall while Matthew was either masturbating or jokingly pretending to do so. The video, taken inside the bathroom, but about 20 feet away from the bathroom stall, did not show Matthew's face, but did reveal his distinctive socks and shoes, which were visible in the gap between the stall wall and the floor. M.H. uploaded the 10-second video to Snapchat with the caption, "I think this dude is jacking off [sic]." M.H. intended the video to be funny and to get a laugh. But about two weeks later, Matthew took his own life, stating in a suicide note, "I can't handle school anymore and I have no friends." The San Diego County District Attorney's Office filed a juvenile delinquency petition alleging M.H. engaged in an unauthorized invasion of privacy by means of a cell phone camera. The trial court found true the allegation that M.H. violated Penal Code section 647(j)(1). The trial court sentenced M.H. to probation on numerous conditions, including several restricting his use of social media. On appeal, M.H. argued: (1) no substantial evidence supported the juvenile court's finding that he had the requisite specific intent "to invade Matthew's privacy" as required by section 647(j)(1); (2) (raised for the first time on appeal) section 647(j)(1) incorporated by reference the elements of the tort of invasion of privacy, and assuming that to be true, he asserts there is a "newsworthy" defense that immunizes him from criminal liability in this case; and (3) (also for the first time on appeal) section 647(j)(1) violated his First Amendment rights. Finding no reversible error, the Court of Appeal affirmed. View "In re M.H." on Justia Law

Woods and other gang members robbed two convenience stores. People were shot during the robberies, but did not die. At the time the government charged Woods he was 20, but at the time of the crime he was 15; under the Juvenile Delinquency and Protection Act, 18 U.S.C. 5031, Woods was considered a juvenile. The government successfully moved to transfer Woods’s case for adult prosecution. The Seventh Circuit affirmed. To charge Woods under the Juvenile Act, the Attorney General was required to certify that the case should be transferred for adult prosecution because it met certain factors, which were not at issue here, and that “there is a substantial Federal interest in the case or the offense to warrant the exercise of Federal jurisdiction.” The government must also submit the juvenile’s court records as a jurisdictional prerequisite to a transfer proceeding. The district court must then consider: the juvenile’s age and social background; the nature of the offense; any prior delinquency record; the present intellectual development and psychological maturity; past treatment efforts and the juvenile’s response; the availability of programs to treat the juvenile’s behavioral problems. In this case, the court thoroughly considered those factors. View "United States v. Woods" on Justia Law

Defendant was indicted as a youthful offender on a charge of involuntary manslaughter. Defendant moved in the juvenile court to dismiss the youthful offender indictment, asserting that the evidence was insufficient to warrant the return of an indictment for involuntary manslaughter where her conduct did not extend beyond words. The juvenile court denied the motion. The Supreme Judicial Court affirmed, holding that the grand jury were justified in returning an indictment of involuntary manslaughter against Defendant because such a conviction is punishable by imprisonment in state prison and involves the infliction of serious bodily harm. View "Commonwealth v. Carter" on Justia Law