Justia Juvenile Law Opinion Summaries

The two defendants in this case were eighteen years old when they pleaded guilty to armed felonies. Both defendants were “youths” within the meaning of N.Y. Crim. Proc. Law 720.10(1), had never been convicted of a crime, and would be eligible to be granted youthful offender status but for the fact that their convictions to be replaced by youthful offender adjudications were armed felonies. At issue on appeal was whether the court in the case of each defendant was required to determine on the record if he was an eligible youth due to the existence of one or more factors set forth in section 720.10(3). The Court of Appeals reversed in each case, holding that, when a defendant who would otherwise be an eligible youth has been convicted of an armed felony, the court is required to make a determination on the record as to whether one or more of the section 720.10(3) factors exists and the defendant is therefore an eligible youth, even if the defendant does not request it or has agreed to forgo youthful offender treatment as part of a plea bargain. View "People v. Middlebrooks" on Justia Law

In January 2008, S.J.C. pleaded guilty to two counts of fourth degree assault with sexual motivation for offenses he committed at age 13. At S.J.C.'s disposition hearing, the juvenile court ordered two years of community supervision and imposed other conditions such as regular school attendance, sexual deviancy treatment, and payment of a victim penalty assessment. After completing all of his conditions, in December 2011, S.J.C. moved to vacate his adjudication and seal his juvenile record under former RCW 13.50.050. The issue this case presented for the Supreme Court's review centered on whether article I, section 10 of the Washington Constitution required the court to apply the "Ishikawa" factors when a former juvenile offender has satisfied the statutory requirements of former RCW 13.50.050 (2011) to seal his or her juvenile court record. "Based on experience and logic," the Court affirmed the juvenile court's holding that it did not. Because it was undisputed that S.J.C. met all the statutory requirements, the Court affirmed the juvenile court's order sealing his juvenile court record. View "Washington v. S.J.C." on Justia Law

Defendant-appellant D.T. (minor) and the victim had been friends before the incident at issue in this appeal. D.T. was 13 years old, and the victim was 14 years old. D.T. and the victim used to play and joke with each other; they did not "rough play." On the day of the incident, the victim was trying to avoid minor and did not want to talk to him. He approached her anyway. When minor pulled at the hood on the victim’s sweater, she tried to pull away and told him to leave her alone. Instead of complying, minor retrieved a pocketknife from his pocket and, while still holding onto the victim’s clothing, opened it so she could see the blade. D.T. poked her multiple times in the upper back with the exposed blade of the knife. The knife felt "sharp" and "pointy," and the victim felt some pain. She did not think D.T. would hurt her, or that he was trying to cut or kill her. However, the victim was scared that an injury might occur because D.T. had a knife pressed to her back. A teacher approached, and D.T. stopped hitting her with the knife and went into class. The victim told both a teacher and a police officer about the incident. When speaking to the police officer, the victim was "visibly upset." On more than one occasion, she told the officer she was scared that minor might hurt her. The police officer noticed a red mark but no broken skin where the victim said she felt the most pain. The police officer escorted D.T. to the assistant principal’s office, where he produced the knife. The two-inch blade was sharp, and the tip of the knife was pointed. D.T acknowledged that the victim told him to stop and was "continually try[ing] to get away from him." According to D.T.'s statements to the police officer, the incident ended when the victim "pulled away and was able to run from him." He expressed remorse and said "he could have hurt" the victim. He also said that he and the victim had been "just playing," and that he did not intend to harm her. After the close of evidence at the jurisdictional hearing, the court found that "the knife in question [was] being used as a deadly weapon." It stated: "The knife blade was open. It was poked numerous times to the back of the victim in this case to the extent that it could have resulted in great bodily injury if more force were to be applied with the use of that knife." On appeal, D.T. argued insufficient evidence supported the allegation that he used a deadly weapon. He asked the Court of Appeal to reduce the allegation the court found true to simple assault. Because the Court of Appeal disagreed about the sufficiency of the evidence, it affirmed the adjudication order. View "In re D.T." on Justia Law

In an original wardship petition (Welf. & Inst. Code, 602), Elias., then 13 years old, was alleged to have committed a lewd and lascivious act upon a child under the age of 14 years, Pen. Code 288(a). Before and at the jurisdictional hearing, defense counsel moved to exclude inculpatory statements Elias made to the police on the ground they were involuntary and inadmissible under Miranda v. Arizona. The motion was denied and the petition sustained. Elias was declared a ward of the court and placed on probation in the home of his parents. Elias claims his confession was involuntary under the due process clause, as it resulted from the type of coercive interrogation techniques condemned in Miranda, The court of appeal reversed. The voluntariness of inculpatory statements made during an interrogation conducted on the basis of no more than the interrogator’s “speculative, intuitive, and risky guess” that the subject is guilty warrants particularly careful judicial scrutiny. The prosecution failed to prove by a preponderance of the evidence that Elias’s inculpatory statements were voluntary. View "In re Elias V." on Justia Law

At ten years of age, Joseph H. woke up early one morning and shot his father in the head as the father lay asleep on a sofa. Joseph had been physically abused and severely neglected by his mother, and was sexually abused by his mother’s boyfriend. Joseph lived with his father Jeff prior to Jeff's death, and Jeff's girlfriend Krista. Jeff was addicted to Percocet and methamphetamine, and was frequently violent towards both Krista and Joseph. A few days before the shooting, Jeff became violent with Krista. Jeff owned guns, which he frequently showed off, including a handgun that was kept in the closet of the bedroom. There were no child protection locks for the gun, which was kept loaded. Krista called 911 when she discovered Jeff on the sofa. When police arrived, Joseph volunteered that he had grabbed the gun and shot his dad in the ear. Joseph explained he did so because his father had beaten him and his mother, and his father had kicked Joseph “in the ass” the day before. Joseph also said he used his father’s gun and that he had put it under his bed after the shooting. When the residence was searched, the gun used in the shooting was found under Joseph’s bed. A wardship petition was filed alleging Joseph had committed acts which would have been crimes if committed by an adult, specifically, murder, with a special allegation of discharging a firearm causing death. After a contested hearing, the juvenile court found that Joseph understood the wrongfulness of his acts despite the statutory presumption of incapacity, had committed an act which would have been second degree murder if committed by an adult, and had discharged a firearm. Joseph appealed his commitment to the Department of Juvenile Justice, arguing: (1) the court erroneously considered statements obtained in violation of his Miranda rights; (2) his evaluation by a prosecution expert during trial, without counsel present, violated his due process rights; (3) the court improperly weighed the evidence in finding that he knew the wrongfulness of his conduct; (4) the true findings must be reversed due to cumulative errors during the adjudicatory hearing; and (5) the court abused its discretion in committing him to the Department of Juvenile J View "In re Joseph H." on Justia Law

This appeal concerned two unrelated cases. In the first case, Defendant pleaded guilty to burglary and misdemeanor theft. Defendant was eighteen years old when the crimes were committed. In the second case, Defendant pleaded guilty to aggravated indecent liberties with a child. Defendant was seventeen years old when the crime was committed. The district court authorized Defendant to be prosecuted as an adult. The cases were consolidated for pleas and sentencings. The district court sentenced Defendant to terms of imprisonment and to a lifetime of supervision once he was released from prison. The court of appeals affirmed, concluding that mandatory lifetime postrelease supervision for juveniles convicted of aggravated indecent liberties does not categorically constitute cruel and unusual punishment under the Eighth Amendment. The Supreme Court reversed, holding that mandatory lifetime postrelease supervision for juveniles who have committed and are later convicted of aggravated indecent liberties with a child is categorically unconstitutional. View "State v. Dull" on Justia Law

J. was born in 1992 in prison and was subsequently abandoned to a stranger in a restaurant. J.’s father was convicted of murder before J.’s birth. The stranger became his guardian, but social services received complaints about living condition and abuse in her home. By 2009, he had lived in 14 placements. He was diagnosed with several psychiatric disorders and lost 19 friends to gang violence. In 2007-2010, multiple criminal petitions were filed against J. He was committed to the Department of Juvenile Justice (DJJ). Before his release, the Juvenile Parole Realignment bill was enacted, eliminating DJJ administered parole, and releasing minors to community based supervision. In 2013, the court ordered that J. be discharged on local probation. The Parole Board did not, as required n the past, make a finding of whether his discharge was honorable. Honorable discharge entitles youths to automatic release from all penalties and disabilities. A condition of probation was that he register as a sex offender. J. became homeless. He moved to Monterey County, but failed to timely notify probation or update his registration. He was arrested while trying to update his registration. Before his probation violation hearing, J’s attorney moved for honorable discharge and relief in juvenile court, arguing that because DJJ no longer makes discharge status recommendations after Realignment, the court should make a finding and relieve J. from the registration requirement. The court of appeal affirmed denial, stating that the Legislature should amend the statutory scheme to be consistent with Realignment View "In re J.S." on Justia Law

The State argued on appeal to the Supreme Court that the trial court erred in ruling that "Miller v. Alabama," (132 S. Ct. 2455 (2012)) applied retroactively to cases on collateral review of a final judgment. Defendant Frank Vigil, Jr. Filed a Crim. P. 35(c) motion for post-conviction relief of his final judgment, arguing that his sentence was unconstitutional under "miller." The trial court applied "Miller" retroactively and granted his motion. The Supreme Court held that "Miller" did not apply retroactively, and reversed. View "Colorado v. Vigil" on Justia Law

Defendants Tenarro Banks and Michael Tate were convicted in 2004 of class 1 felonies for acts committed when they were juveniles. The Supreme Court granted review in defendants' respective cases to determine what remedy was appropriate in light of the federal Supreme Court's decision in "Miller v. Alabama," (132 S. Ct. 2455 (2012)). Under the sentencing scheme in place at the time (which governed offenses committed between 1990 and 2006), both Banks and Tate were given mandatory sentences to life in prison without the possibility of parole (LWOP). While both cases were pending on appeal to the court of appeals, the Supreme Court released its opinion in "Miller." The "Miller" decision rendered the Colorado statutory scheme for mandatory LWOP in place from 1990-2006 as unconstitutional as applied to juveniles. Because the Colorado legislature has not acted to adopt a new sentencing scheme in light of "Miller," so the Colorado Supreme Court was tasked with "filling the gap." For Tate and Banks, the Supreme Court remanded the cases for the trial court to determine wither LWOP was an appropriate sentence under "Miller;" if the trial court determined LWOP was not warranted, life with the possibility of parole (LWPP) was the proper sentence. A third case before the Court on collateral review centered on whether "Miller" applied retroactively: Brendan Jensen was convicted in 1998 of first degree murder while he was seventeen. Under the sentencing scheme in place at the time, his sentence was LWOP. The Court held that the rule announced in "Miller" was procedural rather than substantive in nature, and therefore did not apply retroactively. For Jensen, the Court affirmed the trial court's order denying his motion for post-conviction relief. View "Colorado v. Tate" on Justia Law

The State charged Christopher Maynard in juvenile court with six counts of malicious mischief. Less than one month later, he turned 18 years old. Maynard's counsel did not move for an order to extend the court's statutory jurisdiction before Maynard turned 18. As a result, the juvenile court ruled that it had lost jurisdiction and dismissed the case without prejudice. The State then filed the case in superior court. Maynard moved to dismiss, arguing that preaccusatorial delay and ineffective assistance of counsel deprived him of the benefits of juvenile court jurisdiction, including the opportunity to accept a plea offer from the State. The trial court agreed and dismissed the case with prejudice. On appeal, the Court of Appeals reversed, holding that ineffective assistance of counsel, not preaccusatorial delay, caused the loss of jurisdiction. The court, however, determined that remand to adult trial court for a new trial was the proper remedy. The Supreme Court agreed with the Court of Appeals that Maynard received ineffective assistance of counsel which then deprived him the benefit of the opportunity to accept a plea deal. The Court vacated the Court of Appeals' order with regard to remanding of the case to the adult trial court and instead, directed the State to reoffer the plea proposal of deferred disposition consistent with the Juvenile Justice Act of 1977 (JJA), chapter 13.40 RCW. View "Washington v. Maynard" on Justia Law