Justia Juvenile Law Opinion Summaries

The case revolves around a father, Rene S., who appealed against the jurisdictional and dispositional orders which removed his daughter, F.V., from his custody. F.V. had traveled to the United States from Honduras with her father when she was nine years old, but when they were unable to cross the border together, she entered the United States alone. She was placed with her maternal uncle in California by immigration authorities, who obtained her mother's consent for the placement. The juvenile court sustained allegations that F.V.'s uncle sexually abused her. The court asserted jurisdiction based on the parents allowing F.V. to enter the U.S. unaccompanied with no plan in place for her care.At the disposition stage, the juvenile court indicated it was inclined to return F.V. to her mother in Honduras. However, the court declined to place F.V. with her father, finding his housing situation was unstable and F.V. did not want to relocate to Texas, where her father now lived. As a result, F.V. remained in foster care.The California Court of Appeal reversed the lower court's orders, holding that there was insufficient evidence of future risk to F.V. to support jurisdiction. The court noted that at the time of the jurisdiction hearing, F.V. was no longer in her uncle's custody, and there was no indication that her mother and father would allow her uncle access to her. Given that the father was now in the U.S. and able to care for her, and the mother wanted her back in Honduras, the court found it unlikely that the circumstances leading to F.V.'s entry into the U.S. alone would recur. View "In re F.V." on Justia Law

In this case, the United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of absolute and qualified immunity to two County of San Bernardino social workers, Gloria Vazquez and Mirta Johnson. The plaintiffs, Sydney Rieman and her minor child K.B., alleged that the social workers violated their Fourth and Fourteenth Amendment rights by failing to provide them notice of a juvenile detention hearing and by providing false information to the Juvenile Court about why Ms. Rieman was not noticed for the hearing.The court held that the social workers were not entitled to absolute immunity for their actions and omissions, such as providing false information to the Juvenile Court and failing to give notice of the detention hearing. These actions were not similar to discretionary decisions about whether to prosecute. Absolute immunity did not apply to the plaintiffs' claim that the defendants failed to give them notice of the detention hearing as such notice was mandatory.The court also held that the defendants were not entitled to qualified immunity from suit for failing to provide notice of the hearing. Ms. Rieman had a due process right to such notice and that right was clearly established. The court stated that it was clear at the time that parents could not be summarily deprived of the care and custody of their children without notice and a hearing, except when the children were in imminent danger.Finally, the court held that the defendants were not entitled to qualified immunity for their misrepresentation to the Juvenile Court about why Ms. Rieman was not noticed for the hearing. The court concluded that a reasonable social worker in the defendants' shoes would have understood, based on prior decisional law, that providing incomplete and false information to the Juvenile Court about Ms. Rieman’s whereabouts to convince the court that the social workers had satisfied the due process notice requirement constituted judicial deception. View "RIEMAN V. VASQUEZ" on Justia Law

This case involves the appeal of an order to transfer a juvenile, Miguel R., from the juvenile court system to the criminal court system in California. Miguel was originally charged with murder and other offenses when he was 17 years old. After a juvenile wardship petition was filed, the juvenile court granted a motion to transfer Miguel to the criminal court. The defendant appealed this order, but it was affirmed by the appellate court.Subsequently, changes in legislation led to the case being transferred back to the juvenile court to address the statutory amendments. The juvenile court, applying the new standard of proof, again ordered Miguel to be transferred to the criminal court. Miguel appealed this second order, arguing that the juvenile court misapplied the statutory changes and that the prosecution did not meet its burden under the clear and convincing evidence standard.The appellate court affirmed the order of the juvenile court. It clarified certain points about the recent amendments to the relevant statute, stating that the statute does not require any one factor to be given more weight than others when determining whether a minor is suitable for rehabilitation under the juvenile court's jurisdiction.The appellate court also found that the juvenile court's decision to transfer Miguel to the criminal court was supported by substantial evidence, and that it was not reasonably probable that the juvenile court would have reached a different conclusion even if it had applied the most recent version of the statute. The court's ruling was based on factors such as Miguel's degree of criminal sophistication, his potential for rehabilitation before the expiration of the juvenile court's jurisdiction, the success of previous attempts to rehabilitate him, and the circumstances and gravity of his offenses. View "In re Miguel R." on Justia Law

In the case before the Supreme Court of the State of Kansas, the appellant, the State of Kansas, challenged a trial court's decision to suppress the confession of a minor identified as G.O. The trial court had determined that the confession was not voluntary, and therefore inadmissible. The Court of Appeals reversed the trial court's decision, prompting G.O. to appeal to the Supreme Court.The Supreme Court of Kansas considered whether G.O.'s waiver of his Fifth Amendment rights and his confession were voluntary. Under the Fifth Amendment, an individual has the right to remain silent and not incriminate themselves. This right can be waived if the individual voluntarily, knowingly, and intelligently chooses to speak. The court also examined whether G.O.’s Fourteenth Amendment rights were violated, which protect against involuntary confessions being used as evidence.The court found that while G.O. had been read his Miranda rights, the detective conducting the interview had made misleading statements that suggested G.O. was not in trouble and would not be arrested. The detective further suggested that the purpose of the interview was to help G.O.'s stepsister, which the court found was deceptive.The court also took into account G.O.’s age, his mental health issues, his lack of experience with law enforcement, and his educational struggles. The court concluded that these factors, in combination with the detective’s misleading statements, induced G.O. to confess involuntarily.Therefore, the court held that the trial court was correct in suppressing G.O.'s confession. It reversed the Court of Appeals' decision and affirmed the trial court's judgment. View "State v. G.O." on Justia Law

The case involves a juvenile, D.J.F.-D., who was charged with a gross misdemeanor offense. The juvenile court found D.J.F.-D. incompetent to proceed and suspended the proceedings against him for one year. During this period, the State filed its first notice of intention to prosecute D.J.F.-D., extending the suspension for another year. Subsequently, the juvenile court made two additional findings of incompetency. Before the extended suspension period expired, D.J.F.-D. moved to dismiss the proceedings, arguing that Rule 20.01, subdivision 7(A) of the Minnesota Rules of Juvenile Delinquency Procedure allows the State to file only one notice of intention to prosecute. The juvenile court denied his motion, which was affirmed by the court of appeals in a divided opinion.The Supreme Court of Minnesota was asked to determine whether Rule 20.01, subdivision 7(A), allows the State to file more than one notice of intention to prosecute a child found incompetent to proceed. The court concluded that the rule permits the State to file more than one notice of intention to prosecute, provided that the juvenile court continues to make findings of incompetency. This decision allows the suspension of delinquency proceedings to be extended until the child either regains competency or ages out of juvenile jurisdiction. The court affirmed the decision of the court of appeals. View "In the Matter of the Welfare D.J.F.-D." on Justia Law

In this case, the Supreme Court of Ohio considered whether a juvenile, T.D.S., knowingly, intelligently, and voluntarily waived his Miranda rights before providing statements to the police. The statements related to a homicide investigation involving another juvenile.The case originated from an incident in 2019, where the Police responded to a report of shots fired in an apartment building and discovered a male juvenile, S.G., with gunshot wounds. The police investigation led them to T.D.S., who was then 15 years old. During questioning at T.D.S.'s mother’s house, T.D.S. initially denied involvement in the shooting but later admitted to accidentally shooting S.G. while playing with a gun. After these statements, T.D.S. was read his Miranda rights and questioned further. He was subsequently charged with several offenses including murder and felonious assault.T.D.S. argued that the juvenile court should have granted a motion to suppress all the statements he made to the police officers, contending that he did not knowingly, intelligently, and voluntarily waive his Miranda rights. After considering the totality of the circumstances, including T.D.S.'s age, prior criminal experience, and the nature of the police interrogation, the Supreme Court of Ohio affirmed the lower courts' decisions that T.D.S. had knowingly, intelligently, and voluntarily waived his Miranda rights. The court found that the police did not engage in coercion and that T.D.S.'s waiver was not involuntary.T.D.S. also argued that his post-Miranda statements should be presumed inadmissible under the court's previous reasoning in a case called State v. Farris. However, the court found that T.D.S. had not properly raised this argument in the lower courts, so it was forfeited. Even if he had preserved the argument, the court found that the record did not support his claims under the Farris case.Therefore, the court affirmed the judgment of the lower courts, finding that T.D.S.'s post-Miranda statements were properly admitted at trial. View "In re T.D.S." on Justia Law

In 1980, Thernell Hundley was convicted of capital murder and rape, and received a life sentence without parole. In 2012, the Supreme Court ruled that life sentences without parole for juvenile offenders were unconstitutional, and Hundley's life sentence for capital murder was vacated. However, during his incarceration, Hundley had committed four additional felonies. As a result, the Jefferson County Circuit Court in Arkansas ruled that Hundley was ineligible for parole based on Arkansas Code Annotated section 16-93-607(c)(5), which states that inmates classified as fourth offenders are not eligible for parole.Hundley appealed this decision, arguing that his rape conviction should be vacated as it was merged with the capital murder charge, that he should be eligible for parole under the Fair Sentencing of Minors Act, and that his parole eligibility should be determined by the law in effect when he committed his first crimes in 1979. He also challenged the inclusion of his two Class D felony convictions in determining his parole eligibility.The Supreme Court of Arkansas upheld the circuit court's decision. The court ruled that Hundley's separate conviction for rape was not illegal and could not be vacated. The court further held that Hundley's parole eligibility was correctly determined based on the law in effect at the time he committed his last two felonies in 1988 and 1989, not the law at the time of his original crimes. The court also clarified that Hundley's parole ineligibility was based on his convictions for capital murder, rape, attempted first-degree murder and first-degree battery, not his two Class D felonies. View "Hundley v. Payne" on Justia Law

In this case, the Supreme Judicial Court of Massachusetts was called upon to determine which law applied to the sealing of records from youthful offender proceedings - G. L. c. 276, § 100A, the adult criminal record sealing statute or G. L. c. 276, § 100B, the juvenile delinquency sealing statute. The case arose when the Commissioner of Probation denied the petitioner's request to have his youthful offender records sealed under § 100B and instead applied the adult criminal record sealing statute, § 100A.The court, after examining both statutes and considering the legislative intent, concluded that § 100B, the juvenile delinquency sealing statute, was the proper statute for the sealing of records of youthful offenders. The court found that the Legislature’s intent to aid, encourage, and guide juveniles, which includes youthful offenders, was more consistent with the process outlined in § 100B.The court held that it was an error for the Commissioner of Probation to refuse to seal the petitioner's Juvenile Court records under § 100B, as the petitioner had satisfied all the requirements under the statute. Therefore, the case was remanded back to the county court for the entry of a judgment in favor of the petitioner. View "In the Matter of an Impounded Case" on Justia Law

The Court of Appeal, Fourth Appellate District, Division One, State of California reviewed a case involving a mother (E.V.) who argued that the juvenile court lacked the authority to issue a temporary restraining order (TRO) and a permanent restraining order under Welfare and Institutions Code section 213.5. This section, in conjunction with section 311, implies that such authority is limited to dependency petitions filed by a probation officer rather than petitions filed by a social worker under section 300. The case arose after the juvenile court removed E.V.'s children from her custody due to drug use and negligence. Subsequently, the court granted a TRO request filed by one of the children (A.D.) against E.V. and later issued a permanent restraining order protecting A.D. from E.V. for a three-year period.The court, in this case, rejected E.V's argument, stating that in the context of the statutory scheme, probation officers and social workers are deemed the same. The court cited the legislative authority that allowed the delegation of duties from probation officers to social workers, making both terms interchangeable in juvenile dependency cases. Therefore, the court concluded that the juvenile court had the authority to issue a TRO and a permanent restraining order under Welfare and Institutions Code section 213.5 in cases where the petition was filed by a social worker under section 300. The court affirmed the order of the juvenile court. View "Bonds v. Super. Ct." on Justia Law

In this juvenile wardship proceeding in California, defendant M.B. admitted to attempting murder and related enhancement allegations. M.B. was committed to a secure youth treatment facility (SYTF) for a four-year baseline term of confinement and a maximum term of confinement of 22 years to life. On appeal, M.B. challenged the court's jurisdiction to modify an earlier order setting the maximum term of confinement at four years. He also argued that the indeterminate 22 years to life term was unauthorized and that his precommitment credits should be applied against his four-year baseline term rather than against the maximum term of confinement.The Court of Appeal held that the juvenile court had jurisdiction to enter the challenged order and rejected M.B.'s argument that equal protection principles required application of precommitment credits against the baseline term. However, the court agreed with M.B. and the Attorney General that the 22 years to life maximum term of confinement was unauthorized. As such, the court modified the juvenile court's order to specify the maximum term of confinement as 22 years and otherwise affirmed the order. View "In re M.B." on Justia Law