Justia Juvenile Law Opinion SummariesArticles Posted in Nevada Supreme Court
State v. Eighth Judicial Dist. Court
Logan D. was adjudicated delinquent for lewdness with a minor for an offense that occurred when Logan was seventeen years old. The law at the time of Logan's adjudication provided the juvenile court with discretion to require Logan to submit to adult registration and community notification if it determined that Logan was not rehabilitated. The Legislature subsequently passed a bill mandating that all juveniles ages fourteen an older adjudicated for certain sex offenses register as adult sex offenders and be subject to community notification. Logan and twenty other juveniles filed motions asking the juvenile court to find the bill unconstitutional as applied to juvenile sex offenders. The juvenile court declared the bill unconstitutional as applied to juvenile sex offenders. The State filed a petition for a writ of prohibition or mandamus. The Supreme Court granted the petition, holding that the retroactive application of mandatory sex offender registration and community notification requirements on juveniles adjudicated for certain sex offenses did not violate the due process and ex post facto clauses of the United States and Nevada Constitutions. View "State v. Eighth Judicial Dist. Court" on Justia Law
State v. Javier C.
Respondent was adjudicated delinquent and committed to a state facility. While there, he allegedly battered a group supervisor. The State charged him as an adult with battery by a prisoner under Nev. Rev. Stat. 200.481(2)(f), a felony. Citing relevant statutes and Robinson v. State, which broadly holds that "prisoner" as used in section 200.481(2)(f) was meant to only apply in the criminal setting, the district court dismissed the charge, holding that because Respondent's detention was civil, not criminal, he was not a "prisoner" to whom section 200.481(2)(f) could apply. The State appealed. The Supreme Court affirmed, holding that a juvenile detained for delinquency in a state facility is not a "prisoner" for purposes of section 200.481(2)(f). View "State v. Javier C." on Justia Law