Justia Juvenile Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's sentence of three consecutive terms of life imprisonment, with the possibility of parole after forty-five years, in connection with his conviction of three counts of murder in the first degree, holding that the sentence was within constitutional bounds.Defendant was a juvenile homicide offender and sought resentencing when he was well into adulthood. After the Supreme Judicial Court decided Commonwealth v. Costa, 472 Mass. 139 (2015), the Commonwealth conceded that Defendant was entitled to a resentencing hearing. After a hearing, the sentencing judge reinstated Defendant's sentence. Defendant then filed an application with the Supreme Court pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal from the resentencing judge's ruling, as well as a motion for direct entry of the appeal. The single justice directed entry of the appeal on the question of whether a juvenile homicide offender may be required to serve forty-five years in prison before his first opportunity to seek release based on rehabilitation. The Supreme Judicial Court held that Defendant's sentence did not constitute cruel or unusual punishment in violation of article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. LaPlante" on Justia Law

The Supreme Judicial Court vacated the motion judges' denial of two juveniles' motions to dismiss and remanded these matters to the juvenile court with directions to dismiss each case, holding that the amended definition of "delinquent child" should be applied retroactively to cases pending on July 12, 2018.On or after July 12, 2018, as a result of the enactment of St. 2018, ch. 69, a child who commits an offense before the age of twelve or who commits an infraction or a first offense of a misdemeanor for which the punishment is a fine or imprisonment for not more than six months can no longer be adjudicated a "delinquent child." These cases concerned juveniles who allegedly committed offenses before July 12, 2018 but whose cases remained pending before the juvenile court on or after that date. The juveniles filed motions to dismiss the charges against them on the grounds that the Act's definition of "delinquent child" should apply retroactively to their cases. The motion judges denied the motions. The Supreme Judicial Court granted the juveniles' interlocutory petitions for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the juveniles in these cases were not subject to the Juvenile Court's jurisdiction. View "Lazlo L. v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and the order denying his motion for a new trial, holding that Defendant's sentence was constitutional and that no prejudicial error occurred in the proceedings below.Defendant, who was seventeen years of age at the time of the murder, was sentenced to a mandatory term of life imprisonment with eligibility for parole after fifteen years. The Supreme Judicial Court disagreed, holding (1) a mandatory life sentence with parole eligibility after fifteen years for a juvenile homicide offender convicted of murder in the second degree is constitutional; (2) the judge did not err in denying Defendant's motion to continue his sentence so that he could present evidence related to his juvenile status; (3) the judge did not err in denying Defendant's request to instruct the jury on accident; (4) Defendant's counsel was not ineffective for not requesting other jury instructions; and (5) the judge did not err in denying Defendant's motion to suppress the warrantless "pinging" of Defendant's cellular telephone because no evidence came from the search. View "Commonwealth v. Lugo" on Justia Law

The Supreme Judicial Court reversed the superior court judge’s denial of Defendant’s motion for resentencing, holding that Defendant, a juvenile convicted of armed home invasion, was sentenced to a mandatory minimum term exceeding that applicable to a juvenile convicted of murder without a hearing under Miller v. Alabama, 467 U.S. 460, 477-478 (2012), in violation of the requirements announced in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), and refined in Commonwealth v. Perez, 480 Mass. __ (2018) (Perez II), also decided today.Defendant was adjudicated a youthful offender on indictments charging armed home invasion and various related offenses and was sentenced to a mandatory minimum prison term of twenty years to twenty years and one day on the armed him invasion charge. Defendant later filed a motion for relief from unlawful restraint, which the juvenile court judge denied. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded to the juvenile court for resentencing, holding that Defendant’s sentence violated the proportionality requirement inherent in article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. Lutskov" on Justia Law

The Supreme Judicial Court held that its decision in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), requires sentencing judges to follow an individualized process that allows for the consideration of mitigating circumstances related to the juvenile's age and youthful characteristics before imposing a sentence with a longer period of incarceration prior to eligibility for parole than that applicable to a juvenile convicted of murder.In Perez I, the Supreme Judicial Court determined that Defendant, a juvenile, received a sentence for his nonhomicide offenses that was presumptively disproportionate under article 26 of the Massachusetts Declaration of Rights because the time he would serve prior to parole eligibility exceeded that applicable to a juvenile convicted of murder. On remand, a superior court judge held a hearing to determine whether, in light of the factors articulated in Miller v. Alabama, 467 U.S. 460, 477-478 (2012), the case presented extraordinary circumstances justifying a longer parole eligibility period. The judge then concluded that extraordinary circumstances were present and denied Defendant’s motion for resentencing. The Supreme Judicial Court vacated the order and remanded for resentencing, holding that the hearing judge erred in finding extraordinary circumstances in this case. View "Commonwealth v. Perez" on Justia Law

The Supreme Judicial Court held that, in light of Miller v. Alabama, 567 U.S. 460 (2012), juvenile delinquency adjudications for violent offenses may serve as predicate offenses for adults under the Armed Career Criminal Act (ACCA), Mass. Gen. Laws ch. 269, 10G.Defendant was indicted at age eighteen for unlawful possession of a firearm. Defendant had twice between adjudicated delinquent for crimes of violence, and therefore, the Commonwealth charged Defendant with violating the ACCA. While the case was proceeding, a superior court judge sua sponte raised the issue of whether it was a violation of due process to use juvenile adjudications to enhance sentencing in the same manner as adult convictions. The Supreme Judicial Court allowed Defendant’s application for direct appellate review and held that qualifying juvenile adjudications may be used as a predicate offense for enhanced penalties under Mass. Gen. Laws ch. 269, 10G. View "Commonwealth v. Baez" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Juvenile’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3 challenging the superior court judge’s denial of Juvenile’s petition for bail review, holding that the single justice did not err or abuse his discretion in denying Juvenile’s petition seeking review of the bail determination.Juvenile was charged in a delinquency complaint with being an accessory to murder after the fact and assault and battery by means of a dangerous weapon. A juvenile court judge set bail at $50,000. Juvenile petitioned for a review of the bail determination. The superior court judge denied the petition. The Supreme Judicial Court affirmed, holding (1) the bail determination was appropriately made, and there was no violation of Juvenile’s rights; and (2) therefore, the single justice did not err in denying Juvenile’s Mass. Gen. Laws ch. 211, 3 petition. View "Juvenile v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the judgment of a single justice of the court denying the Commonwealth’s petition for relief from an interlocutory order of the juvenile court, holding that the single justice abused her discretion in declining to employ the court’s power of superintendence to rectify an error of the trial judge.After he was arrested an firearm-related charges, D.M., a juvenile, sought an order requiring the Commonwealth to disclose the identity of its informant and other related information. The judge allowed the juvenile’s motion, determining that the Commonwealth had properly asserted an informant privilege and that D.M. had adequately challenged the assertion of the privilege. The Commonwealth filed a Mass. Gen. Laws ch. 211, 3 petition seeking reversal of the interlocutory ruling and arguing that the judge erred in allowing the juvenile’s motion. The single justice denied the petition. The Supreme Judicial Court reversed, holding that the judge’s analysis was erroneous, and the analytical error should not stand. View "Commonwealth v. D.M." on Justia Law

The Supreme Judicial Court affirmed the adjudication of delinquency as to a juvenile offender under the age of sixteen, holding that, as applied in these circumstances where the juvenile maintained that he was involved in consensual experimentation with another child, enforcement of the statutory rape charge was constitutional.At the time of the alleged offenses, the juvenile was twelve years old and the victim was eight years old. A jury found the juvenile delinquent of statutory rape. On appeal, the juvenile argued that the imposition of criminal liability on a child for a strict liability offense was fundamentally unfair. The Supreme Judicial Court disagreed, holding that the juvenile’s arguments were unable to overcome the presumption that the Legislature acted reasonably and rationally in imposing strict liability for anyone who has sexual intercourse with a child under the age of sixteen. View "Commonwealth v. Wilbur W." on Justia Law

Mass. Gen. Laws ch. 119, 72A permits a juvenile court judge to transfer lesser included offenses when supported by probable cause even where lesser included offenses are not expressly charged.In 2014, juvenile delinquency complaints were issued against Defendant for the crime of rape of a child with force for incidents that occurred when Defendant was sixteen years old. Because Defendant was not “apprehended” until after his nineteenth birthday, the juvenile court judge was faced with discharging Defendant or transferring the charges to adult court. The judge dismissed the offenses charged for lack of probable cause but transferred the lesser included offenses of statutory rape. Defendant filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that because the judge in this case did not inform Defendant of her probable cause rulings on the offenses charged or the lesser included offenses until her decision on the transfer itself, Defendant was not given a meaningful opportunity to present evidence and argument why discharge rather than transfer of the statutory rape charges was consistent with protection of the public. Therefore, Defendant was entitled to reopen the transfer hearing in order to present such evidence and argument. View "J.H. v. Commonwealth" on Justia Law