Justia Juvenile Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Defendant's petition for postconviction relief, holding that, under Minn. Stat. 260B.245, subd. 1(b), delinquency adjudications may be deemed "felony convictions" for the purpose of the statutory definition of a crime of violence.Defendant was charged with possession of a firearm by an ineligible person, which required proof that Defendant had been convicted of a crime of violence. Defendant pled guilty to the offense, admitting that he had been adjudicated delinquent for committing fifth-degree possession of a controlled substance. The district court accepted the plea and placed Defendant on probation. Defendant later filed a petition for postconviction relief, asserting that his juvenile delinquency adjudication failed to satisfy the definition of a "crime of violence" because, under section 260B.245, a delinquency adjudication cannot be deemed a "conviction of crime." The district court denied postconviction relief. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase "felony convictions," as used in the statutory definition of crime of violence, includes a juvenile delinquency adjudication for felony-level offenses listed in Minn. Stat. 624.712, subd. 5; and (2) Defendant provided an adequate factual basis for his guilty plea. View "Roberts v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that two Minnesota statutes - Minn. Stat. 609.749, subd. 2(6), the stalking-by-mail provision, and Minn. Stat. 609.795, subd. 1(3), the mail-harassment statute - are constitutional under the First Amendment, holding that both statutes are facially overbroad.A.J.B. was found guilty of gross-misdemeanor stalking by use of the mail, misdemeanor harassment by use of the mail, and felony stalking. The court of appeals affirmed A.J.B.'s adjudications for stalking by mail and mail harassment, thus rejecting his constitutional challenges. On appeal, A.J.B. argued that his adjudications under the stalking-by-mail provision and mail-harassment statute must be vacated as contravening the First Amendment. The Supreme Court held (1) section 609.749, subd. 2(6), is facially overbroad and not subject to either a narrowing construction or severance of unconstitutional provisions; (2) section 609.795, subd. 1(3), is facially overbroad, but the statute can be saved through severance of the constitutionally problematic language; and (3) because it is unclear whether Defendant's adjudication of delinquency for mail-harassment is based on the severed language, Defendant's adjudication under section 609.795, subd. 1(3), is reversed and the case remanded. View "In re A.J.B." on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The State filed a juvenile delinquency petition against seventeen-year-old C.J.H. Defense counsel at the first appearance told the juvenile court that the parties had agreed to a “continuance for dismissal.” Without finding that the allegations in the charging document had been proved, the juvenile court continued the delinquency proceeding and, approximately nine months later, terminated the continuance. The juvenile court subsequently adjudicated C.J.H. delinquent. C.J.H. appealed, arguing that the proceedings at the first appearance constituted a “continuance without adjudication” because he unconditionally admitted the charged offense. Therefore, C.J.H. argued, under Minn. R. Juv. Delinq. P. 15.05, the juvenile court’s jurisdiction expired before he was adjudicated delinquent. The court of appeals reversed, concluding that the juvenile court’s jurisdiction expired before C.J.H. was adjudicated delinquent. The Supreme Court reversed, holding (1) the plain language of Rule 15.05 requires a juvenile court to find the allegations in the charging document to have been proven before continuing the case without adjudication; and (2) because no such finding was made in this case, the proceedings at C.J.H.’s first appearance did not constitute a continuance without adjudication. View "In re Welfare of C.J.H." on Justia Law

Respondent was adjudicated delinquent of felony burglary and misdemeanor theft. Thereafter, Respondent obtained a district court order expunging his juvenile delinquency records held by the judicial branch and sought to expunge his juvenile delinquency records held by the executive branch. The district court denied the request, but the court of appeals reversed. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) under Minn. Stat. 260B.198(6), the authority of the district court to expunge juvenile delinquency records in executive branch files is limited to the order adjudicating the juvenile delinquent; (2) to determine whether expungement is advisable within the meaning of section 260B.198(6), the district court must weight the benefit to the petitioner against the detriment to the public and the burden on the court; and (3) the district court should decide if Respondent's petition merits expungement by applying the balancing test the Court articulated here to the specific facts and circumstances of the case. View "In re J.J.P." on Justia Law

The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue. View "State v. Grigsby" on Justia Law