Justia Juvenile Law Opinion SummariesArticles Posted in Supreme Court of California
In re I.C.
The Alameda County Social Services Agency filed a petition (Welf. & Inst. Code 300) to have I.C., age three, and her brother, age five, declared dependents of the court, alleging that I.C. had been sexually abused by Father. In a juvenile dependency proceeding, a child’s out-of-court reports of parental abuse are admissible in evidence regardless of whether the child is competent to testify in court (section 355.) but the court may not base its findings solely on the hearsay statements of a child who may not testify because she is too young to separate truth from falsehood unless the child’s statements bear “special indicia of reliability.” The juvenile court found I.C.’s statements to be unclear, confusing, not credible, and unreliable in significant respects but concluded that the indicia of reliability outweighed the indicia of unreliability. The court adjudged her a dependent of the court and ordered her father removed from the home. The Supreme Court of California reversed. The court failed to take adequate account of the confounding role of I.C.’s prior molestation and her subsequent encounter with the prior molester. The timing and content of I.C.’s allegations concerning Father strongly suggested a relationship to her earlier molestation. The court noted that some of I.C.’s allegations were actually false. View "In re I.C." on Justia Law
People v. Contreras
The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law
People v. Superior Court
The defendant was charged in adult criminal court with sex crimes allegedly committed in 2014 and 2015 when he was 14 and 15 years old. The law then in effect permitted the prosecutor to charge the case directly in adult court. After the charges were filed, the electorate passed Proposition 57, the “Public Safety and Rehabilitation Act of 2016,” prohibiting prosecutors from charging juveniles directly in adult court. Such actions must commence in juvenile court. If the prosecution wishes to try the juvenile as an adult, the juvenile court must conduct a “transfer hearing.” Only if the juvenile court transfers the matter to adult court can the juvenile be tried and sentenced as an adult (Welf. & Inst. Code, 707(a)). The Supreme Court of California held that the provision applies retroactively to all juveniles charged directly in adult court whose judgment was not final at the time it was enacted. The possibility of being treated as a juvenile in juvenile court—where rehabilitation is the goal—rather than being tried and sentenced as an adult can result in dramatically different and more lenient treatment, so Proposition 57 reduces the possible punishment for a class of persons, namely juveniles. Nothing in Proposition 57’s text or ballot materials rebuts this inference. View "People v. Superior Court" on Justia Law
In re R.T.
The first clause of Cal. Welf. & Inst. Code 300(b)(1) authorizes a juvenile court to exercise dependency jurisdiction over a child without a finding that a parent is at fault or blameworthy for her failure or inability to supervise or protect her child. The court of appeal also concluded that section 300(b)(1)’s first clause does not require such a finding. In this case, the Los Angeles County Department of Children and Family Services filed a petition to declare then seventeen-year-old R.T. a dependent of the juvenile court on the ground that she faced a substantial risk of serious physical harm or illness as a result of Mother’s failure or inability adequately to supervise or protect her. The juvenile court asserted jurisdiction over R.T. The court of appeal affirmed the jurisdictional and dispositional orders of the juvenile court. The Supreme Court affirmed, holding that when a child’s behavior places her at substantial risk of serious physical harm and a parent is unable to protect or supervise that child, the juvenile court’s assertion of jurisdiction is authorized under section 300(b)(1). View "In re R.T." on Justia Law
In re Albert C.
The Presiding Judge of the Los Angeles County Superior Court, Juvenile Division, issued a protocol addressing the process by which minors are found incompetent and later found to have attained competency. The Supreme Court of California held that although trial courts are not barred from adopting such protocols as guidance or as local rules, the Court of Appeal was correct that the protocol does not presumptively or otherwise define due process. The court declined to decide whether the length of detention in this case violated due process and instead held that any violation was not prejudicial in light of the juvenile court's finding of malingering. Accordingly, the court affirmed the judgment. View "In re Albert C." on Justia Law
K.R. v. Superior Court of Sacramento County
Neither People v. Arbuckle, 587 P.2d 220 (Cal. 1978), nor its progeny support the view that a defendant’s ability to enforce the guarantee that the judge who accepts a plea bargain will impose the sentence (the same-judge guarantee) is dependent on a defendant first making a factual showing that she or he objectively intended the judge taking the plea would also pronounce sentence.K.R., a juvenile, admitted two probation violations. During continued disposition hearings, K.R. filed a petition for writ of mandate requesting that the same-judge guarantee be enforced. K.R.’s claim was denied under Arbuckle, the judge finding that K.R. did not have a reasonable expectation that the judge who accepted his plea would also impose the disposition. The court of appeal agreed and denied K.R.’s petition for writ of mandate. The Supreme Court reversed, holding (1) the plain and original understanding of Arbuckle is that in every plea in both adult and juvenile court, an implied term is that the judge who accepts the plea will be the judge who pronounces sentence; and (2) should the People wish to allow a different judge to preside at sentencing, or, in juvenile cases, disposition, they should seek to obtain a waiver from the pleading defendant or juvenile. View "K.R. v. Superior Court of Sacramento County" on Justia Law
People v. Franklin
Defendant, sixteen-years-old at the time of the offense, was convicted of first degree murder and sentenced to life in state prison with the possibility of parole after 50 years. After plaintiff was sentenced, the United States Supreme Court held in Miller v. Alabama that the Eighth Amendment to the federal Constitution prohibits a mandatory life without parole (LWOP) sentence for a juvenile offender who commits homicide. This court then held in People v. Caballero that the prohibition on life without parole sentences for all juvenile nonhomicide offenders established in Graham v. Florida applied to sentences that were the functional equivalent of a life without parole sentence, including Caballero‘s term of 110 years to life. In this case, the court held that Penal Code section 3051 and section 4801 moot defendant‘s constitutional challenge to his sentence by requiring that he receive a parole hearing during his 25th year of incarceration. In light of this holding, the court need not decide whether a life sentence with parole eligibility after 50 years of incarceration is the functional equivalent of an LWOP sentence and, if so, whether it is unconstitutional in defendant‘s case. Therefore, the court affirmed the sentence. The court remanded so that the trial court may determine whether defendant was afforded sufficient opportunity to make a record at sentencing of mitigating evidence tied to his youth. View "People v. Franklin" on Justia Law
People v. Arroyo
A grand jury returned an indictment against Defendant on charges of conspiracy to commit murder and active participation in a criminal street gang. The grand jury found reasonable cause to believe that Defendant came within the provisions of Cal. Welf. & Inst. Code 707(d)(4). Defendant initially pleaded not guilty but later demurred to the indictment, arguing that section 707(d)(4) requires a determination that a juvenile qualifies for prosecution in adult court, and because he was a juvenile at the time of the alleged offenses, the grand jury had no legal authority to inquire into the charged offenses. The trial court agreed with Defendant, allowed him to withdraw his plea, and sustained his demurrer. The court of appeal reversed. The Supreme Court affirmed, holding that section 707(d) allows prosecutors the option of filing charges against certain juveniles accused of specified offenses in criminal court by grand jury indictment. View "People v. Arroyo" on Justia Law