Justia Juvenile Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

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The Supreme Court reversed the district court’s denial of Defendant’s motion to modify his original sentence after a new individualized sentencing hearing and remanded for a new individualized sentencing hearing.Defendant was seventeen years old when he and his friend robbed and murdered a hitchhiker. Defendant was sentenced to life imprisonment with a consecutive twenty-to-fifty-year sentence for aggravated robbery. Following the decisions in Miller v. Alabama, 567 U.S. 460 (2012), Montgomery v. Louisiana, __ U.S. __ (2016), and Bear Cloud v. State, 294 P.3d 36 (Wyo. 2013), and the Wyoming Legislature’s amendment to Wyo. Stat. Ann. 6-10-301(c), Defendant was granted parole from his life sentence and began serving his consecutive twenty-to-fifty-year sentence. Defendant received a new individualized sentencing hearing, after which the district court declined to modify Defendant’s original sentence. The Supreme Court reversed and remanded for an additional sentencing hearing because at the time of the hearing and the district court’s decision, the parties and the district court did not have the advantage of this Court’s rulings concerning the procedure, burdens, and potentially relevant evidence for a Miller determination contained within this opinion. View "Davis v. State" on Justia Law

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Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

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Appellant was adjudicated a delinquent juvenile for committing a sexual offense that required him to register as an offender under the Wyoming Sexual Offender Registration Act (WSORA). Appellant later entered a conditional guilty plea to two felony counts for failing to report changes in his address, as required by the WSORA. Appellant appealed his convictions, claiming that the WSORA is unconstitutional. The Supreme Court affirmed, holding (1) the Wyoming Juvenile Justice Act does not conflict irreconcilably with the WSORA’s registry requirements for adjudicated juvenile offenders; (2) the WSORA does not violate the Wyoming Constitution’s equal protection clause; (3) Appellant failed to establish that the WSORA’s lifetime registration requirement violates his due process rights; and (4) the WSORA does not violate the ex post facto clause of the United States Constitution. View "Vaughn v. State" on Justia Law

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The State filed a petition in juvenile court alleging that SWM, a minor, had committed two delinquent acts. SWM's counsel filed a motion to suspend proceedings for evaluation under Wyo. Stat. Ann. 7-11-303 and Wyo. Stat. Ann. 14-6-219. The juvenile court granted the motion, determining that sections 7-11-303 and 14-6-219 required an examination of SWM for competency to proceed. After the report under section 7-11-303 was filed, the State filed a motion asking the court to strike the portions of SWM's forensic evaluation that were conducted pursuant to section 7-11-303 as irrelevant to the proceedings. The juvenile court granted the motion and subsequently found SWM was competent to proceed. The Supreme Court reversed and remanded, holding (1) the due process considerations that underlie section 7-11-303 also apply in determining the competency of a minor under section 14-6-219; and (2) although the juvenile court ordered a competency evaluation and ruled that SWM was competent to proceed, it did not evaluate SWM under the correct standards, and therefore, SWM's due process right not to proceed unless competent was not property protected. Remanded. View "In re Interest of SWM" on Justia Law

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K.C., a juvenile, was adjudged delinquent. As part of her disposition, she was allowed to remain in a home environment and placed on supervised probation. After K.C. violated various terms of her probation, her probation was revoked and her disposition changed to placement at a state girls' school for an indefinite period. K.C. appealed. The Supreme Court affirmed, holding (1) the juvenile court did not abuse its discretion in imposing sanctions because placement at the girls' school fell within the statutorily allowable sanctions applicable to K.C. and, thus, the court was not required to provide a written justification for the placement; (2) the juvenile court's consideration of a statement K.C. made that she would not follow the rules of a residential program did not violate K.C.'s right against self-incrimination because the statement was considered only in the dispositional phase of the delinquency proceedings; and (3) there was no violation of Wyo. R. Crim. P. 11 because the rule does not apply to juvenile delinquency proceedings. View "In re K.C." on Justia Law

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The biological mother of the child at issue appealed from the order allowing the father and stepmother's petition to adopt the minor child to proceed without the mother's consent because she did not pay child support for a year before the petition was filed. At issue was whether the district court abused its discretion by allowing the petition for adoption to proceed without the consent of the mother and whether evidence was sufficient to support a finding that the mother had willfully failed to pay child support. The court held that the district court did not abuse its discretion by concluding that there was clear and convincing evidence that the mother willfully failed to support her child where she failed to take the necessary steps to become employed and support her child and that she failed to demonstrate that, through whatever means were available to her, she had not forgotten her legal obligation to support her child. Therefore, the court affirmed the district court's findings.