Justia Juvenile Law Opinion Summaries

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

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