Justia Juvenile Law Opinion Summaries

John Doe, a Native American juvenile and member of the Eastern Shoshone Tribe, was charged in federal court with multiple offenses, including kidnapping a minor on tribal land for the purpose of physical assault. The government filed a six-count juvenile information, and Doe admitted to certain charges, including kidnapping, assault with a dangerous weapon, and provided a factual basis for his admissions. The events occurred in a trailer on the Wind River Indian Reservation, where Doe assaulted two minor victims and instructed one to remain in a closet as he left the scene.The United States District Court for the District of Wyoming held an admission hearing, where Doe, with counsel, admitted to the relevant charges. The court found a sufficient factual basis and conditionally accepted the admissions. After a delinquency hearing, Doe was adjudicated delinquent on several counts and committed to detention and supervision. Following the district court’s judgment, the Tenth Circuit decided United States v. Murphy, which clarified that the “holds” element of federal kidnapping requires proof the victim was detained for an appreciable period beyond that necessary to commit any related offense. Doe appealed, arguing his admission was not knowing or voluntary because he was not informed of this temporal requirement.The United States Court of Appeals for the Tenth Circuit reviewed the case under the plain error standard. The court held that Murphy did not clearly establish the temporal requirement as an essential element of kidnapping, nor did Doe demonstrate that the district court’s failure to inform him of this requirement was a plain error under well-settled law. The court affirmed the district court’s judgment of delinquency. View "United States v. Doe" on Justia Law

A 17-year-old defendant was charged with ten serious offenses, including murder and assault, after a violent confrontation at the home of his rivals. The incident stemmed from a feud with a classmate and escalated when the defendant, accompanied by his family, armed himself and attacked the victims’ home. The attack resulted in the death of one individual and severe injuries to others. The defendant, an enrolled member of the Cherokee Nation, was charged under federal law for crimes committed within the Cherokee Nation Indian Reservation.The United States District Court for the Eastern District of Oklahoma first reviewed the case. The government moved to transfer the defendant from juvenile to adult criminal proceedings under the Juvenile Justice and Delinquency Prevention Act. After an evidentiary hearing, the magistrate judge recommended granting the transfer, and the district court adopted this recommendation after conducting a de novo review. The district court weighed the statutory factors, including the defendant’s age, social background, psychological maturity, prior delinquency record, past treatment efforts, and the availability of rehabilitative programs, and found that most factors favored transfer to adult status.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court did not abuse its discretion in weighing the statutory transfer factors and found no clear error in its factual findings. The court also rejected the defendant’s Eighth Amendment argument that transfer was unconstitutional due to the potential punishments, holding that the challenge was unripe under circuit precedent. The Tenth Circuit affirmed the district court’s order transferring the defendant to adult criminal proceedings. View "United States v. J.D.V., Jr." on Justia Law

A thirteen-year-old girl, D.C., reported to her stepmother that her stepfather, Edgar Rene Garcia-Limon, had sexually abused her over several years, beginning when she was about four and continuing until she was eleven. During the investigation, D.C. described multiple incidents of abuse, and Garcia-Limon admitted to law enforcement and his wife that he had sexually touched D.C. on several occasions. Law enforcement also found firearms in the home, leading to additional charges.The United States District Court for the Eastern District of Oklahoma indicted Garcia-Limon on four counts: felon in possession of a firearm, aggravated sexual abuse of a minor in Indian Country, abusive sexual contact in Indian Country, and illegal reentry. Garcia-Limon challenged the sufficiency of the indictment for the sexual abuse counts, arguing that the eight-year date range was too broad and that the counts improperly charged a scheme rather than specific acts. The district court denied his motions, finding that the indictment properly charged a scheme of abuse and that the counts were not constitutionally defective or duplicitous. At trial, the jury found Garcia-Limon guilty on all counts, and he was sentenced to concurrent terms, including life sentences for the sexual abuse counts.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the indictment was constitutionally sufficient, whether the statutes allowed charging a scheme of abuse, whether the indictment was duplicitous, and whether there was a constructive amendment at trial. The court held that the indictment met constitutional requirements, that the statutes permitted charging a scheme of repeated, similar acts in a single count, and that there was no unconstitutional duplicity or constructive amendment. The Tenth Circuit affirmed Garcia-Limon’s convictions on the challenged counts. View "United States v. Garcia-Limon" on Justia Law

A father was accused of sexually abusing and assaulting his 11-year-old daughter over the course of a single day. The daughter testified to three separate incidents: in the family’s toy room, the father touched her chest through her clothes and showed her a pornographic video; in the school room, he told her they would have vaginal sex that night, described the pain she would experience, touched her vagina through her clothes, and made her touch his exposed penis; later, while driving her to a store, he touched her again, showed more pornographic videos, and, after stopping on a dirt road, moved her onto his lap, sucked on her chest, touched her vagina, kissed her, and asked if she was sure about having sex.A jury in the United States District Court for the Northern District of Oklahoma found the father guilty of abusive sexual contact with a minor under 12 and assault with intent to commit aggravated sexual abuse. After the verdict, the district court entered a judgment of acquittal on the assault charge, reasoning that the evidence was insufficient because the father had said the sex would occur later that night, not immediately. The government moved for reconsideration, and the district court reinstated the conviction, concluding that a reasonable jury could have found both assault and the required intent.The United States Court of Appeals for the Tenth Circuit reviewed three issues: whether the district court plainly erred by not instructing the jury to agree on a specific incident of sexual contact, whether the district court could reinstate the assault conviction after acquittal, and whether sufficient evidence supported the assault conviction. The court held that the omission of a specific unanimity instruction did not affect the defendant’s substantial rights, that the district court could correct its mistaken acquittal without violating the Double Jeopardy Clause, and that sufficient evidence supported the assault conviction. The convictions were affirmed. View "United States v. Roark" on Justia Law

Petitioner-appellant Keighton Budder was convicted by an Oklahoma jury of several violent nonhomicide crimes committed when he was sixteen years old. After sentence modification on direct appeal, he received three life sentences and an additional sentence of twenty years, all to run consecutively. He was not be eligible for parole under Oklahoma law until he served 131.75 years in prison. Budder filed a petition for writ of habeas corpus, arguing his sentence violated the Eighth Amendment. In support, he cited “Graham v. Florida,” (560 U.S. 48 (2010)), which held that sentencing juvenile offenders who have not committed homicide crimes to life in prison without a meaningful opportunity for release was unconstitutional. The district court denied Budder’s petition, and he appeals. The Tenth Circuit reversed and remanded with instructions to grant Budder’s petition. The Court found under the categorical rule clearly established in “Graham,” Budder’s sentence violated the Eighth Amendment. “The [Oklahoma Supreme Court’s] judgment was contrary to this clearly established Supreme Court precedent. Accordingly, we reverse and remand with instructions to grant Budder’s petition for writ of habeas corpus, to vacate Budder’s sentence, and to direct the State of Oklahoma to resentence Budder within a reasonable period.” View "Budder v. Addison" on Justia Law