Justia Juvenile Law Opinion Summaries

Andrew McCurdy entered a plea agreement in February 2022, pleading guilty to felony criminal mischief and agreeing to pay restitution. The District Court ordered a presentence investigation (PSI) report, which included McCurdy’s juvenile records without a Youth Court order. McCurdy filed motions to strike the juvenile records from the PSI and to determine his ability to pay certain fees. The District Court denied the motion to strike, stating the records were provided pursuant to a court order, and imposed a $50 PSI fee and probation supervision costs without inquiring into McCurdy’s ability to pay.The Eleventh Judicial District Court denied McCurdy’s motion to strike his juvenile records, reasoning that the records were provided under a court order and could be considered at sentencing. The court also imposed the PSI fee and probation supervision costs without determining McCurdy’s ability to pay, despite his motion requesting such an inquiry. McCurdy appealed these decisions.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision to include McCurdy’s juvenile records in the PSI, finding that any error in the procedure was harmless as McCurdy did not demonstrate prejudice. However, the Supreme Court reversed the imposition of the $50 PSI fee and probation supervision costs, noting that the District Court failed to inquire into McCurdy’s ability to pay, as required by law. The case was remanded for the District Court to conduct the necessary inquiry into McCurdy’s financial situation before imposing these costs. View "State v. McCurdy" on Justia Law

In the Supreme Court of the State of Montana, defendant Nels Jerry Peterson appealed his conviction on the offense of sexual assault against his eleven-year-old step-granddaughter (Q.H.). The main contention was the District Court’s decision to permit evidence of Peterson’s prior sexual conduct with other young girls under M. R. Evid. 404(b) and 403. The court concluded that some of the evidence may have been admissible for a permissible purpose under Rule 404(b), but the potential for unfair prejudice substantially outweighed its probative value as presented. The details of Peterson’s prior sexual misconduct were not more abhorrent than the current charge. However, the frequency and manner of the State’s references to them throughout the trial risked inducing the jury’s hostility toward Peterson, resulting in unfair prejudice. Further, the State did not meet its burden to show no reasonable possibility that its use of the tainted evidence might have contributed to Peterson’s conviction. Therefore, the court reversed the conviction and remanded the case for a new trial. View "State v. Peterson" on Justia Law

In this case, the Supreme Court of the State of Montana upheld the decision of the Montana First Judicial District Court, Lewis and Clark County, committing the appellant, C.M., a youth, to the custody of the Department of Corrections for placement in a state youth correctional facility until the age of 18. The appellant was charged with sex offenses against three of his high school classmates and he appealed the decision on the grounds that he was denied the right to effective assistance of counsel when his attorney failed to make objections to the admission of various hearsay statements.The court concluded that the appellant's counsel's failure to object to the admission of hearsay statements did not result in substantial prejudice. The court noted that the state presented sufficient admissible evidence to the jury that proved the same facts as the prior consistent statements and bus records. Furthermore, the court found that the appellant's counsel vigorously challenged the complaining witnesses' testimony by highlighting inconsistencies and gaps in their testimony, as well as aspects of the investigation. As a result, the court found that the appellant failed to demonstrate that he was prejudiced by any alleged deficient performance by his counsel and affirmed the lower court's decision. View "Matter of C.M" on Justia Law

The Supreme Court affirmed the order of the district court denying the motion filed by H.M., a youth held in detention, seeking to dismiss a formal petition brought by the State to adjudicate H.M. as a delinquent youth, alleging one count of misdemeanor resisting arrest and three counts of assault on a police officer, holding that the district court did not err in denying the motion.As grounds to dismiss the petition H.M. argued that the State filed it one day beyond the seven-day time limit for such petitions against detained youths in Mont. Code Ann. 41-5-1401(2). The youth court declined to dismiss the petition, concluding that the State had good cause to file the petition and to detain H.M., outside the seven-day deadline. The Supreme Court affirmed, holding (1) the good cause exception in section 41-5-1401(2) applies to the youth court's decision not to dismiss an untimely petition charging a youth held in detention; and (2) the youth court properly denied H.M.'s motion to dismiss. View "In re H.M." on Justia Law

The Supreme Court reversed the judgment of the district court denying Appellant's motion to transfer his criminal case to youth court, holding that the district court abused its discretion by failing to consider Appellant's mitigating and unrequited evidence supporting transfer.Defendant had turned seventeen years old one month before the incident leading to his charges of sexual intercourse without consent, sexual abuse of children, and sexual assault. After a hearing to determine if the case should be transferred to youth court, the district court concluded that transferring the case would be in Defendant's best interests and would serve the interests of community protection but that the transfer should be denied based on the severity of the offense. The Supreme Court reversed, holding that the district court misapprehended the evidence presented by Defendant suggesting that the nature of the offense did not warrant district court prosecution and, instead, impermissibly reached its conclusion based solely on the egregious facts of the offense. View "State v. Johnson" on Justia Law

The Supreme Court reversed the judgment of the district court accepting an imposing a proposed youth court consent decree disposition, placing D.A.T. on supervised conditional probation for two years or until sooner released, and suspending the underlying youth court delinquency proceeding, holding that the youth court erred.At issue before the Supreme Court was whether the youth court erred in concluding that the consent decree guilt admission required by Mont. Code Ann. 41-5-1501(2) constitutes or requires a change of answer under Mont. Code Ann. 41-5-1502(8), thereby effecting a delinquency adjudication. The Supreme Court answered the question in the affirmative and remanded for entry of an amended dispositional order clarifying the effect of D.A.T.'s consent decree admission in according with Mon. Code Ann. 41-5-1501(1). View "In re D.A.T." on Justia Law

The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law

The Supreme Court reversed the oral disposition and accompanying order issued by the Youth Court, which committed V.K.B. to the custody of the Montana Department of Corrections (DOC) for placement at the Pine Hills Youth Correctional Facility following his adjudication as a delinquent youth, holding that the district court exceeded its statutory authority and abused its discretion.V.K.B. was fifteen year old when he accidentally shot and killed another boy. The State filed a delinquent youth petitions alleging that V.K.B. was a delinquent youth. The Youth Court adjudicated V.K.B. a delinquent youth and ordered him to be placed at Pine Hills. The Supreme Court reversed, holding that the district court exceeded it statutory authority and abused it discretion by committing V.K.B. to the DOC for placement at Pine Hills without making the required findings under Mont. Code Ann. 41-5-1513(1)(e) that V.K.B. was a serious juvenile offender and that such a commitment was necessary for the protection of the public. View "In re V.K.B." on Justia Law

The Supreme Court reversed the order of the youth court denying Appellant's motion to dismiss the State's petition to revoke his probation, holding that the youth court erred when it revoked Appellant's probation under a consent decree without Appellant's youth court petition having been reinstated.The youth court relied on the findings from its order to grant two dispositional orders that (1) granted the State's petition to revoke Appellant's probation and imposed a suspended sentence to the Montana Department of Corrections for placement in a secure juvenile facility, and (2) granted the State's second petition to revoke Appellant's probation and committed Appellant to Pine Hills Youth Correctional Facility. The Supreme Court reversed, thus vacating the youth court's two dispositional orders, holding that because the State failed to reinstate Appellant's original youth court petition, the youth court failed to follow the appropriate statutory procedure for a violation of a consent decree. View "In re C.L." on Justia Law

The Supreme Court affirmed the jury verdict and dispositional order finding J.W. guilty of the offense of sexual intercourse without consent - a felony if committed by an adult, adjudicating J.W. a delinquent youth, and designating J.W. a serious juvenile offender, holding that there was no error or abuse of discretion.Specifically, the Supreme Court held (1) the Youth Court did not abuse its discretion when it refused to instruct the jury to consider youth characteristics in determining J.W.'s guilt; (2) the Youth Court did not abuse its discretion when it refused to instruct the jury on the legal age of consent; and (3) there was sufficient evidence to convict J.W. of the offense of sexual intercourse without consent. View "In re J.W." on Justia Law