Justia Juvenile Law Opinion Summaries

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Petitioner Jaryd Schroeder sought treatment from the respondents, Dr. Steven Weighall and Columbia Basin Imaging. Schroeder was nine years old at the time and suffered from headaches, nausea, dizziness, weakness in his legs, and double vision. He underwent an MRI (magnetic resonance imaging), which Weighall reviewed and found to be normal. Schroeder's symptoms persisted. On either November 9 or 19, 2009, when he was 17, Schroeder underwent another MRI. This time the radiologist who reviewed the image found an Arnold Chiari Type I Malformation. On January 13, 2011, the day before his 19th birthday, Schroeder filed a medical malpractice action against Weighall, Columbia Basin Imaging, PC, and a third party subsequently dismissed by stipulation. Weighall asserted that the action was barred by the statute of limitations codified at RCW 4.16.350 and subject to the minority tolling exemption codified at RCW 4.16.190(2). Schroeder and his mother discovered Weighall's alleged omission November 2009 when Schroeder was still a minor. If not for RCW 4.16.190(2), the one-year statute of limitations applicable to his claim would have tolled until his 18th birthday. The ultimate issue before the Supreme Court was the constitutionality of RCW 4. 16. 190(2). Upon review, the Supreme Court concluded that RCW 4.16.190(2) violated article I, section 12 of the Washington State Constitution, and therefore reversed the trial court's summary judgment order dismissing Schroeder's medical malpractice action. View "Schroeder v. Weighall" on Justia Law

D.J.B. was adjudged a juvenile delinquent for acts that would be considered crimes had they been committed by an adult. As an adult, D.J.B. pled guilty to fourth-degree receiving stolen property in 1996. In 2011, D.J.B. filed a petition seeking to expunge his 1996 criminal conviction. The trial court denied the petition, finding that “[t]he combination of N.J.S.A. 2C:52-4.1(a) and N.J.S.A. 2C:52-2 served to prevent a petitioner with an indictable crime from obtaining expungement if that petitioner has a prior juvenile record.” The Appellate Division affirmed substantially for the same reasons. The following month, another appellate panel analyzed a similar question and reached the opposite conclusion about the effect a juvenile adjudication has on an attempt to expunge an adult conviction. After its review, the Supreme Court concluded that based on its language and legislative history, N.J.S.A. 2C:52-4.1(a) applied only to the expungement of juvenile adjudications and did not transform a juvenile adjudication into a “crime” that would bar a later attempt to expunge an adult conviction under N.J.S.A. 2C:52-2. View "In the Matter of the Expungement Application of D.J.B." on Justia Law

Anthony S., then 15 years old, admitted an assault with a firearm, in which he and a co-defendant seriously wounded Houston, resulting in a hospital bill of more than $400,000. The hospital has not attempted to collect from Houston, having determined that he was indigent and the debt was uncollectable. At a hearing to set restitution, a hospital representative testified that after a debt is written off as uncollectable, the hospital generally makes no further attempt to recover it. Nevertheless, the juvenile court t set restitution at 20 percent of $412,546.89 with a credit of $1,000 for the amount that Anthony had already paid to the victim restitution fund, with Anthony and his parents jointly and severally liable. The court of appeal affirmed, rejecting an argument that the restitution order was contrary to Welfare and Institutions Code section 730.6 because there was insufficient evidence of economic loss to Houston. View "In re Anthony S." on Justia Law

In August 2012, then-sixteen-year-old Appellant Stephen W. was charged with possession of marijuana. At the adjudicatory hearing, Appellant moved for a jury trial, claiming that he was entitled to a jury trial under the United States and South Carolina Constitutions. The family court denied Appellant's motion. The family court adjudicated Appellant delinquent and ordered that Appellant spend six consecutive weekends at the Department of Juvenile Justice, complete an alternative educational program, and continue with his prior probation for a period of time not to exceed his eighteenth birthday or until he obtained a G.E.D. Appellant directly appealed to the Supreme Court. He argued that the family court erred in denying his motion for a jury trial in a family court juvenile proceeding. Because there was no constitutional right to a jury trial in a family court juvenile proceeding, the Supreme Court affirmed. View "In the Interest of Stephen W." on Justia Law

A Jefferson County Sheriff Deputy was transporting two juveniles from a court hearing. The two were seated in the rear of the transport van, handcuffed. En route, another driver allegedly turned into an intersection without yielding and collided with the transport van. As a result of the collision, the juveniles sustained multiple injuries. The juveniles sued the County, alleging the deputy transporting them was negligent. The County claimed it was immune from suit. The trial court denied the County's motion to dismiss, and the court of appeals affirmed. Upon review of the County's appeal, the Supreme Court concluded that the trial court erred in finding allegations of negligence alone were sufficient to overcome the statutory grant of immunity and the presumption of good faith afforded to law enforcement. The Court vacated the trial court's order and remanded the case for further proceedings. View "Young v. Jefferson County" on Justia Law

Without holding a hearing, the juvenile court denied two requests by a mother (Karen) to modify an order denying her services to reunify with her three-year-old son and seven-month-old daughter, who had 13 fractures. Later, after holding a hearing, the court terminated her parental rights. The appeals court affirmed, holding that the failure to hold a hearing on the modification requests did not amount to reversible error. On the first request, Karen failed to allege a prima facie case. On the second request, Karen was given an opportunity to be heard, and the court made findings negating the appropriateness of reunification services. Her parental rights were properly terminated because substantial evidence supports showed that the potential benefit to the children from a continuing relationship with mother was outweighed by the benefits of adoption. View "In re G.B." on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

The issue this case presented to the Supreme Court centered on whether the district court properly ordered the defendants to register as sex offenders pursuant to La. Rev. Stat. 15:542(A). The more precisely: whether the defendants, who, as adults, entered pleas of guilty to the charge of indecent behavior with a juvenile for conduct that occurred when the defendants were themselves under the age of 14 years old, had to register as sex offenders under the statute even though they would not have been required to register as such had they entered guilty pleas as juveniles in juvenile court at the time they committed the offenses. The Supreme Court found under the plain language of the statute that the defendants qualified as “[a]ny adult residing in this state who has pled guilty to … a sex offense as defined in R.S. 15:541…” and, therefore, must register as sex offenders pursuant to La. Rev. Stat. 15:542(A)(1). View "Louisiana v. I.C.S." on Justia Law

The Commonwealth filed five delinquency complaints against Defendant when he was seventeen years old based on the alleged sexual abuse of a victim. Defendant was summonsed into court on the complaints while he was still seventeen, but Defendant had turned eighteen by the time of his first scheduled court appearance and arraignment. The Commonwealth subsequently obtained youthful offender indictments against Defendant based on the portion of the alleged abuse that took place when Defendant was between fourteen and seventeen years old. The juvenile court subsequently reported to the Supreme Court questions concerning issues of the juvenile court's jurisdiction. The Supreme Court held (1) the term "apprehended" in Mass. Gen. Laws ch. 119, 72 is marked by the commencement of process, typically through a summons, provided the individual is able to the court at that time; (2) an individual may not be indicted as a youthful offender after he has turned eighteen for offenses he allegedly committed between the ages of fourteen and seventeen; and (3) a youthful offender indictment may not issue against an individual after his eighteenth birthday, regardless of whether a delinquency complaint on the same facts has been filed before the individual's eighteenth birthday.View "Commonwealth v. Mogelinski" on Justia Law