Justia Juvenile Law Opinion Summaries

A juvenile was seen masturbating in a parked car and was charged with open and gross lewdness and lascivious behavior, a felony. At trial, the jury was also instructed on the lesser included offense of indecent exposure, a misdemeanor punishable by no more than six months in jail. The jury found the juvenile delinquent only of the lesser included offense. The juvenile, who had no prior offenses, argued that the delinquency adjudication must be dismissed for lack of subject matter jurisdiction.The Juvenile Court judge denied the motion to dismiss and sentenced the juvenile to a continuance without a finding until his nineteenth birthday, after which the charge was dismissed. The juvenile appealed, and the Supreme Judicial Court transferred the case from the Appeals Court to address whether the Juvenile Court retained jurisdiction over a first offense of a minor misdemeanor after a jury trial.The Supreme Judicial Court concluded that once the jury found the juvenile delinquent only of a minor misdemeanor and it was undisputed that it was his first offense, the Juvenile Court no longer had subject matter jurisdiction. The court held that the delinquency adjudication should have been dismissed and recorded only as a Wallace W. determination. The court vacated the adjudication of delinquency and remanded the matter to the Juvenile Court with instructions to make the appropriate entry. View "Commonwealth v. Vince V." on Justia Law

In two separate cases, mothers petitioned the Juvenile Court to involuntarily commit their children for inpatient care due to substance use disorders under Massachusetts General Laws c. 123, § 35. E.S. was committed for ninety days, and J.P. for thirty days, following hearings where family members and court clinicians testified about the juveniles' substance use and behaviors.In the case of E.S., the Bristol County Juvenile Court judge found clear and convincing evidence of a substance use disorder, citing E.S.'s history of alcohol and marijuana use, recent positive tests for fentanyl, and concerning behaviors such as stumbling and passing out. The judge also found a likelihood of serious harm due to the imminent risk posed by E.S.'s substance use and the lack of immediate outpatient care options. E.S.'s commitment was affirmed on appeal.For J.P., the Essex County Juvenile Court judge ordered commitment based on testimony about J.P.'s daily marijuana use, behavioral changes, and a single incident of driving under the influence. However, the court clinician did not find J.P. to be a danger to himself or others. On appeal, the Supreme Judicial Court found the evidence insufficient to support a likelihood of serious harm, noting the lack of clear evidence of imminent risk. J.P.'s commitment order was reversed.The Supreme Judicial Court of Massachusetts held that a finding of a substance use disorder under § 35 must be supported by clinical evidence to comply with substantive due process. The court affirmed E.S.'s commitment but reversed and vacated J.P.'s commitment, remanding the case for entry of an order consistent with its opinion. View "In the Matter of J.P." on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

The case involves a nonmarital child who was removed from the mother's custody due to neglect. The Department of Children and Families filed a care and protection petition in the Juvenile Court. The father, who had established paternity but had not sought custody prior to the filing of the petition, was granted temporary custody. The mother later waived her right to a hearing and stipulated that she was unfit, leading to the Juvenile Court judge awarding "permanent" custody to the father. However, the child filed a motion to dismiss the care and protection case, arguing that the Juvenile Court's custody order was sufficient to award permanent custody to the father.The Juvenile Court judge denied the child's motion, citing the statutory scheme which addresses the rights and responsibilities of the parents of nonmarital children. This scheme provides that the mother of a nonmarital child "shall" have custody "[i]n the absence of an order or judgment of a [P]robate and [F]amily [C]ourt [judge] relative to custody." The current practice in the Juvenile Court is to require the parent, who has been awarded permanent custody of the child in connection with a care and protection action, to seek an order of custody from the Probate and Family Court under the nonmarital child statutory scheme.The Supreme Judicial Court of Massachusetts affirmed the Juvenile Court judge's order denying the child's motion to dismiss the care and protection case. The court agreed that the current practice best reflects the Legislature's intent and harmonizes the two statutory schemes. The court also concluded that the practice complies with due process. View "Care and Protection of Jaylen" 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