Justia Juvenile Law Opinion Summaries

Petitioner, the prosecuting attorney of Ohio County, West Virginia, filed a juvenile petition against J.Y., a twelve-year-old boy charged with possession of a deadly weapon on the premises of an educational facility. Specifically, J.Y. possessed the deadly weapon with the express intent to intimidate another student. The circuit court dismissed the petition, finding that J.Y. was not competent to stand trial and that the charged offense did not involve “an act of violence against a person.” Petitioner sought a writ of prohibition to prevent the circuit court judge from dismissing the juvenile petition, asserting that J.Y. was charged with an offense that involved “an act of violence against a person” within the meaning of W. Va. Code 27-6A-3 given the potential for harm to other students that existed as a result of J.Y.’s actions. The Supreme Court granted the requested writ, holding that J.Y.’s actions indicated that he posed a risk of physical harm and severe emotional and psychological harm to children, and therefore, J.Y. committed an offense involving an act of violence against a person within the meaning of section 27-6A-3. View "State ex rel. Smith v. Hon. David J. Sims" on Justia Law

Defendant was convicted of murder in the second degree for the shooting of a fourteen-year-old. Defendant was seventeen years and five months old at the time of his arrest for the shooting. Defendant appealed the district court’s denial of his motion to suppress incriminating statements that he made to the police after waiving his Miranda rights, arguing that their introduction at trial was error given the common-law rule that, ordinarily, a juvenile must be given a meaningful opportunity to consult with an interested adult before waiving his Miranda rights, an opportunity he did not have. Several years after Defendant was convicted, the Legislature enacted St. 2013, ch. 2013 (2013 act), which amended various statutory provisions to treat seventeen year olds as juveniles. The Supreme Judicial Court affirmed Defendant’s conviction, holding (1) the 2013 act did not affect this case because it is prospective in its application and does not modify the interested adult rule; but (2) the interest adult rule is now extended, on a prospective basis, to seventeen year old defendants. View "Commonwealth v. Smith" on Justia Law

In this case, the Third District Court of Appeal read Graham v. Florida as creating a homicide-case exception to the categorical rule against sentencing a juvenile offender to life without parole for a nonhomicide crime. The court’s reading would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception, the Third District held that Defendant’s life-without-parole sentences for certain nonhomicide offenses committed as a juvenile were constitutional under Graham because Defendant also committed a homicide in the same criminal episode. The Supreme Court quashed the Third District’s decision, holding that Graham’s categorical rule leaves no room for the homicide-case exception recognized by the state’s Second, Third, and Fourth District Courts of Appeal. Remanded with instructions that Lawton be resentenced for the nonhomicide offenses of attempted first-degree murder with a firearm and armed robbery with a firearm. View "Lawton v. State" on Justia Law

A Minnesota jury convicted Martin of first-degree murder, committed at age 17. Martin received a mandatory life sentence without possibility of release. The Minnesota Supreme Court affirmed and rejected a challenge to the jury’s composition under Batson. Martin filed a habeas petition under 28 U.S.C. 2254. While it was pending, the U.S. Supreme Court held that mandatory life sentences without parole for defendants who commit homicide before age 18 violate the Eighth Amendment. Martin argued that Miller applied retroactively to him. The district court denied the petition. The Eighth Circuit affirmed. Miller does not apply retroactively on collateral review. The Minnesota Supreme Court did not unreasonably determine that the trial court properly rejected Martin’s Batson challenge. View "Martin v. Symmes" on Justia Law

R.T. was born in 1996. When R.T. was 14, she began running away for days at a time, not attending school, falsely reporting that her mother abused her, and at least once throwing furniture. R.T. began having children when she was 15. Mother went looking for R.T. whenever she left home; arranged for R.T. to live with mother’s parents because R.T.’s grandfather used to work with troubled juveniles and because R.T.’s false reports were made when R.T. and mother were alone; called the police for help; and asked the Los Angeles County Department of Children and Family Services for assistance. She declined to voluntarily submit R.T. to the Department’s jurisdiction. R.T. remained “out of control.” The Department filed a petition to declare then-17-year-old R.T. a dependent of the juvenile court under Welf. & Inst. Code 300(b)(1). The court asserted jurisdiction, denying mother’s motion to dismiss, and issued a dispositional order authorizing the Department to place R.T. elsewhere while reunification services were provided. The Department placed her back with her grandparents. The court of appeal affirmed. Regardless of parental blameworthiness, when a child faces a substantial risk of serious physical harm, a parent’s inability to supervise or protect a child is enough to invoke dependency jurisdiction. View "In re R.T." on Justia Law

A petition filed in 2008 by the Los Angeles County Department of Children and Family Services (DCFS) alleged that D.A., born late 2007, and his half-brother Z.S., born early 2006, were at risk of harm under Welfare and Institutions Code section 300. The children had been living with mother, who had a history of violent altercations with father in the children’s presence and were placed together in foster care. In 2009 father was incarcerated. DCFS recommended that family reunification services be terminated. Mother gave birth to K.A. in 2009. Father was found to be K.A.’s presumed father. K.A. had tested positive for marijuana at birth and mother’s marijuana use interfered with her ability to care for him. In 2013 the court terminated parental rights and finalized the adoptions of the children. The court of appeal dismissed father’s appeal as untimely and an appeal by maternal grandmother for lack of standing. Father, who failed to maintain contact with DCFS, visited the children only sporadically, and often did not appear at noticed hearings even while not incarcerated, did not explain how the result of the hearing would have been different if there had been perfect compliance with notice requirements. View "In re Z. S." on Justia Law

Petitioner was involved in a fist-fight with another high school student, Dylan P., who suffered a broken nose and damaged sinuses. Pursuant to a plea agreement, Petitioner admitted involvement in the alleged affray. The juvenile court determined that Petitioner committed the offense of affray and placed him on probation. The circuit court subsequently amended Petitioner’s probation to require Petitioner to pay partial restitution for the medical offenses incurred by Dylan P. for treatment of his injuries suffered during the affray. The intermediate appellate court affirmed the order of restitution. The Court of Appeals reversed, holding (1) trial courts are not statutorily authorized to order restitution in favor of a person who is a voluntary and willing participant in the crime or delinquent activity that caused his or her injury; and (2) because Dylan P. fought willingly with Petitioner, the circuit court erroneously required Petitioner to pay restitution to Dylan P. View "In re Tyrell A." on Justia Law

In August 2000, when Jimmy Williams, Jr. was 15 years old, he was convicted of murder made capital because it was committed during a robbery. In accordance with the applicable law at the time of Williams's sentencing, the trial court sentenced Williams to life imprisonment without the possibility of parole, the only possible sentence and one that was mandatory. The Court of Criminal Appeals affirmed Williams's conviction and sentence. In June 2013, Williams petitioned the circuit court, asserting that under the rule announced by the United States Supreme Court in "Miller v. Alabama," (132 S.Ct. 2455 (2012)), the mandatory sentence of life imprisonment without the possibility of parole to which he was sentenced in 2000 for an offense committed when he was 15 years old was unconstitutional and, consequently, that he was entitled to be resentenced based on the individualized sentencing factors discussed in Miller. The issue in this case presented for the Alabama Supreme Court's review was whether "Miller" applied retroactively to Williams' case. Because Miller did not categorically forbid a sentence of life imprisonment without parole for a juvenile defendant and because Miller did not apply retroactively, Williams's sentence of life imprisonment without the possibility of parole was legal. The Alabama Supreme Court concluded the Court of Criminal Appeals did not err in denying Williams the relief he requested. View "Ex parte Jimmy Williams, Jr." on Justia Law

Aaron S. was adjudged a dependent minor when he was 16 years old and became a non-minor dependent when he turned 18,Welf. & Inst. Code, 11400(v). The juvenile court terminated dependency jurisdiction shortly before Aaron turned 19, finding that by not enrolling in school or having a job, Aaron failed to participate in his Transitional Independent Living Case Plan. Aaron claimed that the Santa Clara County Department of Family and Children’s Services did not provide him a 90-day transition plan. The court of appeal affirmed. Even assuming the issue was not forfeited, termination without proof of a 90-day transition plan was harmless here because the Department separately provided information to Aaron regarding each of the categories that would have been included in the plan. For housing, employment, educational and continuing support services information, the emancipation letter that was mailed to Aaron before the termination hearing referred him to his Independent Living Program case manager and provided contact information for Transitional Housing Program providers. That letter also informed Aaron he was eligible for health benefits through Medi-Cal, and the section 391 report indicated the Department mailed Aaron a copy of the advanced health care directive form. View "In re Aaron S." on Justia Law

Defendant was convicted of murder in the second degree and received a mandatory sentence of life imprisonment with eligibility for parole after fifteen years. Defendant was fifteen years old at the time of the offense. Defendant appealed, arguing, among other things, that his mandatory life sentence constituted cruel and unusual punishment in violation of the Eighth Amendment to the U.S. Constitution and article 26 of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) a mandatory life sentence with eligibility for parole after fifteen years for a juvenile homicide offender convicted of murder in the second degree does not offend the Eighth Amendment or article 26 or other constitutional rights; and (2) Defendant’s challenges to his underlying conviction were without merit. View "Commonwealth v. Okoro" on Justia Law