Justia Juvenile Law Opinion Summaries

When he was 17 years old, M.W. assaulted his girlfriend. After a Welfare and Institutions Code section 602 petition was filed, seeking to have him declared a ward of the juvenile court, M.W. admitted to willful infliction of corporal injury. The juvenile court adjudged M.W. a ward of the court and ordered him to reside in his mother’s home under the probation department’s supervision and to complete a 52-week “Batterer’s Intervention Program” because M.W. had a “pattern of engaging in violent behavior, as well as inappropriateness with females.”M.W. requested that the court order the probation department to pay for the program. M.W. had already enrolled in the program at a cost of $153 per month, approximately $1,800 for the 52-week program. The court denied M.W.’s request. The court of appeal reversed. Under the Welfare and Institutions Code, neither M/W/ nor his mother is liable for the costs of his treatment program. A court may not impose liability on a minor’s parents unless authorized by statute; a minor may be liable for costs only in very limited instances. The People cite no authority to support an order imposing the costs of the Batterer’s Intervention Program on M.W. or his family. View "In re M.W." on Justia Law

The Supreme Judicial Court vacated the denial of Defendant's Mass. R. Crim. P. 30(a) motion seeking to vacate his remaining sentences after he was paroled from his life sentence for murder and remanded the matter to the superior court for a hearing, holding that the motion judge failed to consider the specific circumstances and unique characteristics of Defendant as a juvenile.In 1996, Defendant, who was seventeen, committed crimes that resulted in his guilty plea to murder in the second degree, armed assault with intent to murder, and illegal possession of a firearm. Defendant was sentenced to life imprisonment for murder and two sentences of five to seven years' imprisonment for the assaults to run concurrent to each other but consecutive to the life sentence. After Defendant was paroled from his life sentence he moved to vacate the remaining sentences and for resentencing under Rule 30(a). The motion judge denied the motion. The Supreme Judicial Court remanded the matter to consider whether Defendant's sentences comported with article 26 of the Massachusetts Declaration of Rights, holding (1) 120 Code Mass. Regs. 200.08 distinguishes parole for life sentences from other sentences and is therefore invalid; and (2) because Defendant already served the aggregate minimum of his sentences, he was immediately entitled to a parole hearing. View "Commonwealth v. Sharma" on Justia Law

A juvenile wardship petition charged Noah with several crimes, such as motor vehicle burglaries and vandalism; he entered a plea admitting one felony motor vehicle burglary count. While Noah’s wardship was ongoing, a supplemental juvenile wardship petition alleged Noah, then 14 years old, committed attempted robbery and caused or permitted an elder or dependent adult to suffer. A video showed Jacqueline, the 88-year-old victim, leaving a restaurant. As she opens the car door, a young man runs up. Her husband, Philippe, got into the driver’s seat. When Jacqueline steps aside to let the young man pass, he grabs her purse and starts to run, dragging Jacqueline behind the car, where she falls, slams into the ground, and rolls, still holding the purse. A police officer took fingerprints from where the young man touched the car; they matched Noah’s. Jacqueline was still on the ground when the officer arrived; she was confused and bleeding.The juvenile court sustained the allegations and found the attempted robbery adjudication qualified as an offense under Welfare and Institutions Code section 707(b) and committed Noah to a ranch facility for 12 months with a 180 day “aftercare period.” The court of appeal affirmed. Noah’s adjudication for attempted robbery is an offense described in Penal Code section 1203.09 and falls within Welfare and Institutions Code section 707(b). Substantial evidence showed Noah’s intent to rob Jacqueline and that he inflicted great bodily injury. View "In re Noah S." on Justia Law

The issue presented for the New Jersey Supreme Court's consideration was whether defendant Zakariyya Ahmad’s statement to police -- which occurred when defendant was 17 years old and without his being advised of his Miranda rights -- was properly admitted at his trial for multiple offenses related to the murder of a cafe owner in Newark, New Jersey. The Appellate Division affirmed, agreeing that defendant was questioned as “part of an investigatory procedure rather than a custodial interrogation” and that Miranda was therefore not implicated. The Supreme Court found admission of the statement was harmful error: a reasonable 17-year-old in defendant’s position would have believed he was in custody and not free to leave, so Miranda warnings were required. View "New Jersey v. Ahmad" on Justia Law

Juvenile J.S. appealed a circuit court’s finding of delinquency based on petitions alleging criminal mischief, simple assault and attempted simple assault. The petitions were filed after a series of events in September 2020 at the Mount Prospect Academy, a non-secure detention facility whose students are placed there due to behavioral issues. At the close of the State’s case at the adjudicatory hearing, the court granted the juvenile’s motion to dismiss one of the petitions for insufficiency of evidence, and denied his motions to dismiss the remaining petitions for lack of subject matter jurisdiction. The latter motions argued that the court lacked subject matter jurisdiction because the State failed to comply with RSA 169- B:6, III and IV. On appeal, the juvenile argued the trial court “erred as a matter of law in determining that, on the undisputed facts in the record here, Mount Prospect Academy is not a school.” Accordingly, he contended the court erred by failing to dismiss the delinquency petitions. The New Hampshire Supreme Court upheld the trial court’s determination on the facts presented in this case, that Mount Prospect was not a “school” for purposes of RSA 169-B:6, III and IV. Accordingly, the Court upheld the trial court’s denial of the motions to dismiss and affirm the finding of delinquency. View "In re J.S." on Justia Law

In 1996, Dorsey (age 14) kicked open a door to a Chicago takeout restaurant and began firing a gun at customers, killing a 16-year-old and severely injuring 13-year-old Williams and 16-year-old Sims. At the hospital, Williams told police that Dorsey, whom she knew from school, was the shooter. The juvenile court allowed Dorsey’s prosecution to proceed in adult criminal court. Dorsey was convicted of first-degree murder and two counts of attempted first-degree murder. A presentence report detailed Dorsey’s troubled home life, gang involvement, and previous encounters with the law. While awaiting trial, Dorsey obtained an eleventh-grade education with “very good grades.” The court heard extensive evidence in aggravation and in mitigation then sentenced Dorsey to consecutive terms, resulting in an aggregate sentence of 76 years’ imprisonment.In 2014, Dorsey sought leave to file a successive petition for postconviction relief, arguing that his aggregate sentence violated the Eighth Amendment and the Supreme Court’s Miller v. Alabama holding, which forbids “a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders.” He argued that, although his sentence is not technically a natural life sentence, such a lengthy sentence imposed on a juvenile is sufficient to trigger Miller-type protections.The Illinois Supreme Court held that good-conduct credit is relevant and that a sentence imposed pursuant to a statutory scheme that affords a juvenile an opportunity to be released from prison after serving 40 years or less of the term imposed does not constitute a de facto life sentence. View "People v. Dorsey" on Justia Law

The Supreme Court dismissed for lack of jurisdiction this appeal brought approximately nineteen years after a district court adjudicated I.A. as a juvenile offender, holding that due process and procedural fairness did not require this Court to hear I.A.'s out-of-time appeal.I.A. pled guilty to two counts of reckless aggravated battery for acts he committed when he was seventeen years old. About nineteen years after his sentencing, I.A. filed a pro se request to file a direct appeal out of time, arguing that the judge had not announced his right to appeal. The court of appeals held that it did not have jurisdiction and dismissed the appeal. The Supreme Court affirmed, holding that Kansas appellate courts lack jurisdiction to hear an appeal if a juvenile offender did not follow statutory directives, and due process did not require the Court to make an exception. View "In re I.A." on Justia Law

Juvenile N.M. appealed the family division’s order granting the request of the Department for Children and Families (DCF) to place him in an out-of-state secure facility. Juvenile argued he was entitled to an independent, second evidentiary hearing, pursuant to 33 V.S.A. 5291(d), on the question of whether he should be placed in the secure facility. The Vermont Supreme Court concluded section 5291(d) was inapplicable in the post-disposition phase of this case, and therefore denied the request. Insofar as juvenile made no other arguments in support of his appeal, the appeal was dismissed. View "In re N.M., Juvenile" on Justia Law

The Supreme Court reversed the judgment of the district court revoking the suspended portion of Appellant's sentence, holding that the district court did not err in denying Appellant's motion to dismiss for lack of subject matter jurisdiction.When Appellant was sixteen, the youth court found Appellant to be a delinquent youth, and Appellant received a juvenile disposition consisting of both a juvenile sentence and an adult sentence. After Appellant admitted to violations of the conditions of his sentence the judge implemented the adult sentence in modified form. The State later filed a second petition to revoke, and the judge revoked Appellant's deferred adult sentences and sentenced him to a term of incarceration. When Appellant was twenty-seven years old the State filed a third petition to revoke. Appellant filed a motion to dismiss, arguing that the youth court's jurisdiction over him ended when he reached the age of twenty-five and that the judge had not transferred the case to the district court. The judge denied the motion. The Supreme Court reversed, holding (1) the youth court lost jurisdiction over Appellant when he reached his twenty-fifth birthday and the case was not transferred to a district court; and (2) the lower court lacked jurisdiction and imposed an illegal sentence. View "In re S.G.-H.M. Jr." on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming Petitioner's convictions and the judgment of the circuit court denying Petitioner's motion to transfer jurisdiction to the juvenile court pursuant to Md. Code Crim. Proc. 4-202, holding that the circuit court did not properly consider Petitioner's amenability to treatment in a juvenile institution, program, or facility.Petitioner was charged with several crimes that he committed when he was sixteen that were beyond the jurisdiction of the juvenile court. After the circuit court denied Petitioner's motion to transfer jurisdiction to the juvenile court Petitioner entered a conditional guilty plea. The court of special appeals. The Court of Appeals reversed and remanded the matter for a new hearing on Petitioner's motion to transfer, holding that it was evident from the circuit court's remarks that it did not properly consider amenability. View "Davis v. State" on Justia Law