Justia Juvenile Law Opinion Summaries

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

At issue was whether the holding in Commonwealth v. Newton N., also decided today, that where a prosecutor wishes to proceed to arraignment on a delinquency complaint supported by probable cause, a juvenile may not dismiss the complaint before arraignment on the grounds that dismissal is in the best interests of the child and in the interests of justice, also limits judicial authority to dismiss a delinquency complaint brought by a private party under Mass. Gen. Laws. ch. 218, 35A, where a clerk-magistrate issued the complaint after finding probable cause. The Supreme Judicial Court held (1) the limitation set forth in Newton N. applies only where the prosecutor has affirmatively adopted the private party’s complaint by moving for arraignment, rather than simply appearing at the scheduled arraignment; and (2) where the prosecutor has not moved for arraignment, a judge considering a juvenile’s motion to dismiss before arraignment may consider whether the clerk-magistrate appropriately exercised sound discretion in issuing the complaint and, in so doing, may consider whether dismissal is in the best interest of the child and in the interests of justice. View "Commonwealth v. Orbin O." on Justia Law

At issue in this appeal from the Juvenile Court’s grant of a prearrangement motion to dismiss a delinquency complaint, the Supreme Judicial Court held (1) a judge, in weighing whether the information contained within the four corners of the complaint application and attached exhibits establishes probable cause, may not consider whether a juvenile was criminally responsible for the charged offenses or whether the juvenile’s mental impairment rendered the juvenile incapable of having the requisite criminal intent; and (2) where a prosecutor proceeds to arraignment on a delinquency complaint supported by probable cause, the judge may not dismiss the complaint prior to arraignment on the grounds that dismissal of the complaint is in the best interests of the child and in the interests of justice. The Supreme Judicial Court held that, in this case, the dismissal of the delinquency complaint before arraignment was improper because the complaint was supported by probable cause and the prosecutor wished to proceed to arraignment. The court vacated the order of dismissal and remanded the matter to the Juvenile Court. View "Commonwealth v. Newton N." on Justia Law

Where an individual has been released on bail pursuant to Mass. Gen. Laws ch. 276, 58 and there is probable cause to believe the individual committed a crime while released on bail, the Commonwealth may seek to revoke bail under either Mass. Gen. Laws ch. 276, 58 or Mass. Gen. Laws ch. 276, 58B. The judge must then make a determination as to whether the Commonwealth satisfied the requirements of either section 58 or section 58B, under which it sought to revoke bail.Here, the judge found probable cause to believe that a juvenile had committed a crime while released on bail under section 58. The juvenile argued that the judge erred in applying the ninety-day revocation period under section 58B. Specifically, the juvenile argued that the statutes create an ambiguous bit revocation framework, and therefore, the rule of lenity requires the applicable of the sixty-day revocation period under section 58. The Supreme Judicial Court disagreed, holding (1) the bail revocation scheme is not ambiguous in its current form, and therefore, the rule of lenity does not apply; and (2) revoking bail under section 58B where an individual has been released on bail pursuant to section 58 and subsequently commits a crime while on release, does not violate due process. View "Josh J. v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3 arguing that because he had been “lawfully committed to the Department of Youth Services” at the time he committed the crime of murder, he was entitled to a transfer hearing pursuant to Mass. Gen. Laws ch. 119, 61, which was then in effect. The single justice concluded that Petitioner was not entitled to a transfer hearing because, when the murder occurred in 1995, a seventeen-year-old was an adult in the eyes of the juvenile and criminal law. The Supreme Judicial Court affirmed, holding (1) because a seventeen-year-old was not, at the relevant time, considered a “child,” the juvenile court did not have jurisdiction over the matter; and (2) the fact that Petitioner had previously been committed to the Department was of no relevance because Petitioner would not have been subject to the juvenile court’s jurisdiction in any event. View "Elliot v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner’s petition filed under Mass. Gen. Laws ch. 211, 3 arguing that when the Commonwealth seeks to indict a juvenile, the grand jury must be instructed on the basic differences between juvenile and adult brains. Petitioner based his argument on the court’s decision in Commonwealth v. Walczak, 463 Mass. 808 (2012), which requires that a grand jury be instructed on the elements of murder and the significance of mitigating circumstances and defenses when the Commonwealth seeks to indict a juvenile for murder. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner’s arguments in support of his petition were unavailing. View "Cepeda v. Commonwealth" on Justia Law