Justia Juvenile Law Opinion Summaries

The Pennsylvania Supreme Court granted discretionary review to resolve inconsistencies between the Superior Court’s decisions in Commonwealth v. Kemp, 961 A.2d 1247 (Pa. Super. 2008) and Commonwealth v. Nguyen, 116 A.3d 657 (Pa. Super. 2015), specifically with regard to whether information obtained by a police officer during a lawful initial traffic stop may be used to justify re-engagement with the driver after the police officer indicates the driver is free to go, such that consent to search given during that re-engagement is valid. The Supreme Court concluded, under the circumstances of this case, the consent given was valid and suppression of evidence was not warranted. View "In the Int. of: A.A." on Justia Law

J.B., a juvenile, appealed the Superior Court’s order affirming the juvenile court's order adjudicating him delinquent. J.B. was charged for the first-degree murder and homicide of an unborn child in connection with the shooting death of his stepmother inside their family home on the morning of February 20, 2009. J.B. argued that there was insufficient evidence to support his adjudication of delinquency beyond a reasonable doubt for these offenses, and, alternatively, that the juvenile court’s adjudication was against the weight of the evidence. The Pennsylvania Supreme Court's careful review of the evidentiary record in this matter compelled its conclusion that the evidence introduced at his adjudicatory hearing was indeed insufficient, as a matter of law, to establish his delinquency for these offenses beyond a reasonable doubt. As a result, the Court reversed the Superior Court’s order which affirmed the juvenile court’s order of disposition for these offenses. View "In The Interest of J.B.; Appeal of: J.B." on Justia Law

Appellant Qu’eed Batts was convicted of a first-degree murder that he committed when he was fourteen years old. The issue for the Pennsylvania Supreme Court’s review was whether the sentencing court imposed an illegal sentence when it resentenced him to life in prison without the possibility of parole. After careful review, the Court concluded, based on the findings made by the sentencing court and the evidence upon which it relied, that the sentence was illegal in light of Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S.Ct. 718 (2016). Pursuant to its grant of allowance of appeal, the Court further concluded that to effectuate the mandate of Miller and Montgomery, procedural safeguards were required to ensure that life-without-parole sentences were meted out only to “the rarest of juvenile offenders” whose crimes reflected “permanent incorrigibility,” “irreparable corruption” and “irretrievable depravity,” as required by Miller and Montgomery. The Pennsylvania Court recognized a presumption against the imposition of a sentence of life without parole for a juvenile offender. To rebut the presumption, the Commonwealth bears the burden of proving, beyond a reasonable doubt, that the juvenile offender is incapable of rehabilitation. View "Pennsylvania v. Batts" on Justia Law

The case centered Section 6105 of the Pennsylvania Uniform Firearms Act of 1995. Although a Section 6105 violation, by default, is graded as a misdemeanor of the first degree, subsection (a.1)(1) elevated the offense grade to a felony of the second degree where the defendant was “convicted” of any felony offense enumerated in subsection (b). In 2011, Appellee was convicted, among other things, of a Section 6105 offense, apparently based upon his possession of a firearm and the fact of a previous juvenile adjudication in 2005 for conduct which would give rise to an aggravated assault conviction if committed by an adult. Prior to sentencing, the prosecution apparently took the position that the finding of delinquency should be considered a “conviction” for purposes of the subsection (a.1)(1) enhancement. On appeal, however, the Superior Court vacated the sentence and remanded for resentencing. The intermediate court explained that the term “conviction” carried a discrete legal connotation that is not generally understood to encompass juvenile adjudications. The Supreme Court granted review to determine whether juvenile adjudications of delinquency qualify as “convictions” for purposes of grading within a particularized sentencing regime. The Court held that the concept of convictions, as embodied in Section 6105, did not encompass juvenile adjudications. View "Pennsylvania. v. Hale" on Justia Law