Justia Juvenile Law Opinion Summaries

After two commitment hearings, the juvenile court entered an order committing Alan L. to the Office of Juvenile Services (OJS) for commitment at a youth rehabilitation and treatment center. In its first order, the court concluded that the State had not proved the necessary conditions for commitment, but the court subsequently found that the evidence supported a commitment order. Alan appealed, arguing (1) claim preclusion barred the State from presenting any new evidence at the second commitment hearing that was available to it before the first commitment hearing; and (2) the commitment hearing violated his right to due process because he could not confront and cross-examine individuals who provided adverse information against him. The Supreme Court affirmed, holding (1) Alan was not deprived of his right to procedural due process despite the State’s failure to comply with case law for seeking a new disposition or commitment to OJS; and (2) new evidence at the second commitment hearing, which became available after the first hearing, showed a change of circumstances warranting Alan’s commitment to OJS, and claim preclusion does not bar consideration of changed circumstances. View "In re Interest of Alan L." on Justia Law

Minor and his friends entered an Oakland home through a back window and took a watch, a camera, and loose change. They were apprehended blocks away. The dispositional report noted that Minor had a “difficult” relationship with his mother and admitted he had experimented with drugs and alcohol and had associated with members of the Norteños gang. Minor was in danger of failing most of his middle school classes. He had significant behavioral issue. The juvenile court placed Minor under the supervision of the probation department and imposed probation conditions, including a 6:00 p.m. curfew, a no-contact order as to the victim and Minor’s co-offenders, and requirements that Minor attend school, complete his school work, remain drug-free, submit to regular drug testing, and submit to a search of his person, residence, vehicles, containers, and “electronics, including passwords.” Minor unsuccessfully moved to delete the electronic search condition. The court stated that Minor “has some fairly substantial drug issues” and “we need to use the electronics to make sure we can monitor the purchase, or sales, usage [of drugs].” The court of appeal affirmed, holding that the condition was not overbroad, was reasonably related to potential future criminality, and was necessary to ensure compliance with other conditions. View "In re J.E." on Justia Law

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law

Sixteen-year-old M.H. used his smartphone to surreptitiously record a fellow high school student, Matthew B., in a school bathroom stall while Matthew was either masturbating or jokingly pretending to do so. The video, taken inside the bathroom, but about 20 feet away from the bathroom stall, did not show Matthew's face, but did reveal his distinctive socks and shoes, which were visible in the gap between the stall wall and the floor. M.H. uploaded the 10-second video to Snapchat with the caption, "I think this dude is jacking off [sic]." M.H. intended the video to be funny and to get a laugh. But about two weeks later, Matthew took his own life, stating in a suicide note, "I can't handle school anymore and I have no friends." The San Diego County District Attorney's Office filed a juvenile delinquency petition alleging M.H. engaged in an unauthorized invasion of privacy by means of a cell phone camera. The trial court found true the allegation that M.H. violated Penal Code section 647(j)(1). The trial court sentenced M.H. to probation on numerous conditions, including several restricting his use of social media. On appeal, M.H. argued: (1) no substantial evidence supported the juvenile court's finding that he had the requisite specific intent "to invade Matthew's privacy" as required by section 647(j)(1); (2) (raised for the first time on appeal) section 647(j)(1) incorporated by reference the elements of the tort of invasion of privacy, and assuming that to be true, he asserts there is a "newsworthy" defense that immunizes him from criminal liability in this case; and (3) (also for the first time on appeal) section 647(j)(1) violated his First Amendment rights. Finding no reversible error, the Court of Appeal affirmed. View "In re M.H." on Justia Law

Woods and other gang members robbed two convenience stores. People were shot during the robberies, but did not die. At the time the government charged Woods he was 20, but at the time of the crime he was 15; under the Juvenile Delinquency and Protection Act, 18 U.S.C. 5031, Woods was considered a juvenile. The government successfully moved to transfer Woods’s case for adult prosecution. The Seventh Circuit affirmed. To charge Woods under the Juvenile Act, the Attorney General was required to certify that the case should be transferred for adult prosecution because it met certain factors, which were not at issue here, and that “there is a substantial Federal interest in the case or the offense to warrant the exercise of Federal jurisdiction.” The government must also submit the juvenile’s court records as a jurisdictional prerequisite to a transfer proceeding. The district court must then consider: the juvenile’s age and social background; the nature of the offense; any prior delinquency record; the present intellectual development and psychological maturity; past treatment efforts and the juvenile’s response; the availability of programs to treat the juvenile’s behavioral problems. In this case, the court thoroughly considered those factors. View "United States v. Woods" on Justia Law

Defendant was indicted as a youthful offender on a charge of involuntary manslaughter. Defendant moved in the juvenile court to dismiss the youthful offender indictment, asserting that the evidence was insufficient to warrant the return of an indictment for involuntary manslaughter where her conduct did not extend beyond words. The juvenile court denied the motion. The Supreme Judicial Court affirmed, holding that the grand jury were justified in returning an indictment of involuntary manslaughter against Defendant because such a conviction is punishable by imprisonment in state prison and involves the infliction of serious bodily harm. View "Commonwealth v. Carter" on Justia Law

Elijah C. signed a document waiving the one-year statute of limitations for petty theft as a condition of entering a diversion program for first-time offenders. The court held that a minor’s purported waiver of the statute of limitations for an offense is not valid, when that waiver was made without consultation with counsel and before a petition against the minor was filed. Although Elijah did not yet have the right to counsel under the Sixth Amendment because no petition had yet been filed, he faced what was in effect a critical stage of the prosecution. Accordingly, the court reversed the juvenile court's order overruling the demurrer. View "In re Elijah C." on Justia Law

A petition was filed with the juvenile court alleging that George F. committed a lewd and lascivious act upon a child under the age of 14, and that George willfully annoyed and molested a child under the age of 18. The State offered to dismiss count 1 if George admitted to count 2. George admitted to count 2 and the juvenile court found a factual basis for that admission. The court then granted the State's motion to dismiss count 1, declared George a ward of the court, and ordered him to juvenile probation on various terms and conditions. George appealed, contending that the conditions of his probation restricting his use of electronics or requiring the submission of those electronics to search were invalid under "California v. Lent (15 Cal.3d 481 (1971)) and (2) unconstitutionally overbroad. Finding no reversible error, the Court of Appeal affirmed. View "In re George F." on Justia Law

Petitioner D.C. appealed the denial of post-conviction relief (PCR), alleging that the change-of-plea hearing that preceded his adjudication of juvenile delinquency was constitutionally inadequate. The superior court held that the PCR statute did not apply to juvenile delinquency proceedings and that the only remedy available to petitioner was through 33 V.S.A. 5113 and Vermont Rule of Civil Procedure 60(b), but that route was foreclosed because petitioner’s claim was untimely raised. On appeal, petitioner argued that the case was not moot, despite the fact he was over the age of majority at the time of his appeal (and no longer committed to state custody), and that the PCR statutes permitted juveniles to collaterally attack their adjudications. After review, the Vermont Supreme Court agreed, reversed the superior court’s order dismissing petitioner’s PCR complaint, and remanded for further proceedings. View "In re D.C." on Justia Law

K.H.-H., a 17-year-old male, was charged with assault with sexual motivation after he forced himself on C.R., a female acquaintance who attended the same high school. The issue this case presented on appeal involved whether a juvenile disposition condition requiring K.H.-H. to write an apology letter to the victim violated his constitutional free speech rights. After review, the Supreme Court held that it did not. View "Washington v K. H.-H." on Justia Law