Justia Juvenile Law Opinion Summaries

The State sought certiorari for review of a decision of the Court of Criminal Appeals that reversed the Juvenile Court's decision to deny G.M.'s motion to suppress evidence that G.M. argued was obtained pursuant to an illegal search. The matter was one of first impression for the Supreme Court: whether evidence of a public-school student's association with an individual known to be involved in criminal activity and suspected of being affiliated with a gang, without more, constituted reasonable grounds for a search of the student by a school official under the Fourth Amendment. The Supreme Court concluded that it did not. Therefore, the Court affirmed the Court of Criminal Appeals' judgment.View "G. M. v. Alabama " on Justia Law

Minor Nicholas Proulx was injured in a car accident and treated for his injuries at Memorial Hospital at Gulfport. Nicholas' parents Timothy and Hope Proulx obtained letters of guardianship and petitioned the chancery court for authority to compromise and settle Nicholas' personal injury claim. The guardians also asked the court to dismiss claims against the settlement proceeds made b several medical providers, including Memorial. Memorial appealed the dismissal of its claim against the settlement. Because Memorial had no assignment, lien or other legal right to payment from the settlement proceeds, the Supreme Court affirmed the chancery court's dismissal of Memorial's claim.View "Memorial Hospital at Gulfport v. Proulx" on Justia Law

Following the denial of her motion for new trial, Chanell Pitts appealed her convictions and misdemeanor sentences for 2011 violations of OCGA 20-2-690.1(the "mandatory education statute"). Her sole challenge was to the constitutionality of the statute. Finding no error in the trial court’s denial, the Supreme Court affirmed. View "Pitts v. Georgia" on Justia Law

Alonzo J. was charged in a juvenile court delinquency petition with two felony counts of assault with a deadly weapon by means of force likely to produce great bodily injury. The juvenile court appointed attorney Jo Ann Harris to represent Alonzo on the charges. The prosecution offered a plea deal under which Alonzo could return home on probation if he admitted to committing one felony assault. Alonzo wanted to accept the offer, but Harris refused to consent. The juvenile court would not accept Alonzo’s admission of guilt without Harris’s consent, and, after a hearing, sustained all charges against Alonzo. The court then directed that Alonzo be placed in a foster or group home, a residential treatment center, or the home of a friend or relative. The court of appeal reversed, holding that although Harris’s consent was required for an admission of the charges, it was not required for a no contest plea, and the juvenile court should have allowed Alonzo to accept the plea offer by pleading no contest. The Supreme Court reversed, holding that, in a delinquency proceeding, the consent of the child’s attorney is required for a no contest plea, just as it is for an admission of the charging allegations. View "In re Alonzo J." on Justia Law

A Cal. Welf. & Inst. Code 602 wardship petition was filed alleging that D.B. committed a series of criminal offenses, including serious or violent offenses. A juvenile court found the allegations true, sustained the petition, and committed D.B. to the Department of Corrections and Rehabilitation, Division of Juvenile Facilities (DJF) for the maximum term. The court of appeal reversed, concluding that the plain language of Cal. Welf. & Inst. Code 733(c) prohibits a DJF commitment when the minor’s most recent offense is not listed in Cal. Welf. & Inst. Code 707(b) or Cal. Penal Code 290.008(c). The People appealed, arguing that the court of appeal’s interpretation could produce absurd consequences when a juvenile’s violent crime spree happens to end with a nonviolent offense. The Supreme Court affirmed, holding that the plain language of section 733(c) mandates that a minor may not be committed to DJF unless the most recently committed offense that is alleged in any wardship petition, then admitted or found true, is listed in section 707(b) or section 290.008(c). View "In re D.B." on Justia Law

Michael and April are the biological parents of Avalyn, born out of wedlock in 2002. A court ordered Michael to pay child support but did not order visitation. In 2005, the state took temporary emergency custody of Avalyn after April attempted suicide. The county sought an adjudication under Neb. Rev. Stat. 43-247(3)(a), but did not give Michael notice. Avalyn was placed in foster care with her maternal grandmother in April’s home. Michael claims that because he was paying support through the state, caseworkers knew or should have known how to contact him. About six months after the disposition he received notice and intervened. The court placed Avalyn with Michael until November 2007, when the parties stipulated that Avalyn should be placed with April but divide her time between her parents. In a suit under 42 U.S.C. 1983, Michael alleged that in failing to notify him of the juvenile proceedings, the defendants interfered with constitutional rights to familial integrity, substantive due process, and equal protection and that the Nebraska statutes were unconstitutional. The Nebraska Supreme Court held that claims against state defendants for monetary damages were barred by sovereign immunity; qualified immunity shielded employees from liability in their individual capacities because they did not violate a clearly established right. Claims for declaratory and injunctive relief were not barred. In a juvenile proceeding alleging abuse, neglect, or dependency, due process requires notice and an opportunity to be heard for a child’s known adjudicated or biological father who is providing substantial and regular financial support; the statutes at issue are not facially unconstitutional, but cannot be constitutionally applied to avoid notification. View "Michael E. v. State" on Justia Law

Defendant, twelve years old at the time of the offense, appealed his conviction for sexually abusing his six year old cousin. The court concluded that the certification that the government filed in the district court met the requirements of 18 U.S.C. 5032 by certifying that "the juvenile court or the state does not have jurisdiction over the juvenile with respect to the alleged act of juvenile delinquency," even though it was missing a page and did not include a statement of the government's substantial federal interest in this case. Guided by the United States v. Kim factors, considering the totality of the circumstances of defendant's detention, and taking into account defendant's status as a juvenile, the court concluded that a reasonable person in defendant's position would not have felt free to terminate the questioning and leave the police station. Therefore, defendant was "in custody" during his interrogation by the detective. Defendant was never read his Miranda rights and his inculpatory statements during his interrogation by the detective must be suppressed. Defendant's younger brother, who was seven at the time of trial and five at the time of the offense, was competent to testify as a witness. The evidence at trial, including defendant's inculpatory statements, was not insufficient to support the conviction. The court reversed and remanded, however, because the inculpatory statements were obtained in violation of defendant's Miranda rights and should have been suppressed. View "United States v. IMM" on Justia Law

Robert Lee Colton Dietsch appealed his conviction for sexual assault of a twelve-year-old girl. Dietsch was seventeen at the time of the alleged assault. The State charged Dietsch as an adult. Dietsch moved to transfer prosecution from the district court to the youth court. The district court denied the motion. Dietsch later entered into a plea agreement whereby he agreed to plead guilt to one count of sexual assault in exchange for the State's agreement to drop a sexual consent without consent charge. Ultimately Dietsch received a deferred sentence of six years and sixty days. On appeal to the Supreme Court, Dietsch argued the district court abused its discretion in refusing to transfer his case to the youth court. The Supreme Court concluded sufficient evidence supported the district court's decision. However, the Court concluded the district court erred in its imposition of certain conditions on Dietsch, including setting an indeterminate amount for restitution, and failing to retain jurisdiction over the case until Dietsch reached age 21. Accordingly, the Court remanded the case for further proceedings.View "Montana v. Dietsch" on Justia Law

J.S., a juvenile, was adjudicated as a delinquent for burglary and battery under two separate juvenile petitions and placed in a level four juvenile detention facility until he reached the age of twenty-one. The Supreme Court affirmed, holding (1) even if J.S. was wrongfully denied a detention hearing on the burglary petition and a preliminary hearing on the battery petition, the errors were harmless; (2) any error in not filing a timely adjudicatory order on the burglary petition was harmless; (3) the circuit court did not err in considering certain hearsay evidence at the disposition hearing; (4) the circuit court did not abuse its discretion in placing J.S. in a level four juvenile detention facility; and (5) the circuit court’s failure to advise J.S. of his right to appeal was not reversible error. View "State v. J.S." on Justia Law

In 1990, defendant, then 14 years old, was arrested for two fatal shootings. Following a discretionary hearing under the Juvenile Court Act, the court allowed defendant to be prosecuted under the criminal laws. He was convicted of two first degree murders, attempted first degree murders of two others, and home invasion. Because defendant was convicted of murdering more than one victim, the Unified Code of Corrections, 730 ILCS 5/5-8-1(a)(1)(c), required a term of natural life imprisonment, with parole not available. He was also sentenced to 30 years for each attempted murder and home invasion, all to run concurrently. The appellate court affirmed. In 1996-1998 defendant filed three post-conviction petitions. All were dismissed; the appellate court affirmed the dismissals. In 2002, defendant filed another petition, arguing that the natural life sentence was unconstitutional because defendant did not actually participate in the act of killing; that the sentence violated the Eighth Amendment; and that the statute requiring a mandatory life sentence violated the Illinois Constitution as applied to a 14-year-old. The circuit court dismissed, noting that defendant carried a weapon and actually entered the abode where the murders occurred. The appellate court affirmed. Defendant another petition in 2011, arguing violation of the Eighth Amendment in light of the Supreme Court’s 2010 decision, Graham v. Florida, and ineffective assistance because counsel failed to interview an eyewitness before the juvenile hearing. The court denied the petition. While appeal was pending, the Supreme Court decided in Miller v. Alabama (2012), that “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments.’ ” The appellate court concluded that Miller applies retroactively on post-conviction review and remanded for a new sentencing hearing, but upheld denial of the ineffective assistance claim. The Illinois Supreme Court affirmed. View "People v. Davis" on Justia Law