Justia Juvenile Law Opinion Summaries

At a hearing before a Juvenile Court judge, a juvenile admitted to sufficient facts with respect to two counts of indecent assault and battery on a person fourteen or older. The juvenile subsequently filed a motion seeking relief from the obligation to register as a sex offender. A judge denied the juvenile’s motion for relief from registration, determining that the juvenile posed a risk of reoffense and would be required to register with the Sex Offender Registry Board. The Supreme Court affirmed, holding that the judge’s ultimate determination that the juvenile should not be relieved of the obligation to register as a sex offender did not constitute an abuse of her discretion. View "L.L. v. Commonwealth" on Justia Law

A 2006 juvenile delinquency petition alleged that then-16-year-old J. unlawfully took or drove a motor vehicle; received stolen property; and committed conspiracy. J. entered a negotiated admission to count 1 as reduced to a misdemeanor; counts 2 and 3 were dismissed. The juvenile court established wardship and placed him on probation in the custody of his parents. Months later, that court ordered J. to pay restitution of $2,357.65, jointly and severally with a co-responsible. At a subsequent hearing, the probation officer stated that J. had not made any payment, but had agreed to begin making bi-weekly payments. As of about five months later, he had paid $251, leaving a balance of $2,106.65. About three months later, J. cut off his electronic monitoring device and ran away. After he was apprehended, J. acknowledged the restitution debt. The court later signed an Order for Restitution and Abstract of Judgment, for J. and his parents and a co-responsible to pay the restitution, terminated probation, and dismissed the wardship. The court of appeal affirmed, rejecting an argument that the order must be vacated because it was issued after J. turned 21 years old, the age at which the juvenile court’s jurisdiction terminated. View "In re J.V." on Justia Law

For the second time, Croft sought the Seventh Circuit’s approval to pursue a successive petition for a writ of habeas corpus under 28 U.S.C. 2254, relying primarily on the 2012 Supreme Court decision, Miller v. Alabama, that the Eighth Amendment forbids sentences of mandatory life in prison without parole for juvenile offenders. Because he was 17 when he committed murder, aggravated kidnapping, and aggravated sexual assault, Croft argues that his sentence of natural life imprisonment without parole for the murder is unconstitutional under Miller. The Seventh Circuit denied the petition, stating that even if it were to hold that Miller applies retroactively on collateral review, Miller is inapplicable to Croft’s case. Life sentences for murder are discretionary under Illinois law, a critical difference from the situation presented in Miller, which considered only “mandatory life-without-parole sentences for juveniles.” The sentencing court explicitly stated that it had considered the presentence report, which discussed Croft’s age. The appellate court underscored the discretionary nature of Croft’s sentence when it reviewed the ample justifications supporting it, including the fact that Croft’s crimes were among the most brutal the court had ever seen. View "Croft v. Williams" on Justia Law

A petition was filed under Welfare and Institutions Code section 602 alleging that the 16-year-old minor had committed a misdemeanor violation of Penal Code section 653.22, loitering with intent to commit prostitution. The minor moved to exclude evidence on the ground that she was a victim of human trafficking. The minor called as witnesses, Investigator Robison of the Concord Police Department Special Victims Unit and Sergeant Price of the Concord Police Department Special Enforcement Team. The court found there was insufficient evidence that the minor was a victim of human trafficking and denied the motion. At the contested jurisdictional hearing, Officers Robison and Price repeated their prior testimony regarding the events and circumstances they observed leading to the minor’s arrest. The court found the allegation that the minor loitered with intent to commit prostitution to be true, declared the minor a ward of the juvenile court, placed her on probation, and ordered her to reside in her father’s home. Among other probation conditions, the court ordered her to attend school regularly and “use [her] best efforts in doing well.” The appeals court affirmed, rejecting claims of ineffective assistance of counsel and that the conditions of probation were unconstitutionally vague. View "In re M.D." on Justia Law

Fifteen-year-old D.S. was accused of harassing a peer during an after-school confrontation. The State filed a petition alleging that D.S. had committed a delinquent act, specifically harassment in the third degree. After an adjudicatory hearing, the juvenile court concluded that the State had proven beyond a reasonable doubt that D.S. committed harassment in the third degree by means of intimidation. The court then adjudicated D.S. to have committed a delinquent act. The Supreme Court reversed, holding that there was insufficient evidence in the record to support the finding that D.S. committed harassment, and therefore, the juvenile court erred when it adjudicated D.S. delinquent under the harassment statute. Remanded for an order dismissing the petition. View "In re Interest of D.S." on Justia Law

Appellant, a juvenile, was convicted and sentenced. The Supreme Court reversed Appellant’s sentence, instructing that, if a sentence of life according to law was imposed, the district court must specify a period of parole ineligibility. The district court did as instructed and imposed a sentence of life according to law with the specification that Appellant was eligible for parole on the sentence after thirty-five years. The Supreme Court vacated the sentence imposed by the district court, holding that Appellant should be resentenced because the district court did not consider the analysis from Miller v. Alabama “in light of the entire sentencing package.” View "Sen v. State" on Justia Law

Pierce Township Officer Homer responded to a call from S.L.’s mother and “smelled smoke.” S.L.’s mother stated that her teenage son had set fires in the house and that she had found smoldering Popsicle sticks in his bedroom. Homer entered S.L.’s bedroom. Popsicle sticks were not visible, but S.L. allegedly admitted that he had the fire. Homer asked whether he was afraid that the house might catch fire. S.L. responded, “I really don’t care.” Homer arrested S.L. for aggravated arson, transported him to the Juvenile Detention Center, and prepared a complaint charging S.L. as delinquent. Bartley, a deputy clerk, signed the complaint, attesting that Homer had taken an oath in his presence, but never administered the oath. S.L. appeared 12 hours later before Judge Wyler, who scheduled the pre-trial hearing and ordered continued detention pending psychological evaluation. S.L. was released a week later; the charge was dismissed. S.L. sued. Concerning claims against Homer under 42 U.S.C. 1983, the district court held that a genuine dispute of material fact existed on probable cause for arrest. Concerning Bartley, the court held that there is no duty for a detention clerk to make an independent assessment of probable cause and that a genuine dispute of material fact existed as to whether Bartley had legal authority to administer oaths. The court denied summary judgment for the township because the judge did not make a probable-cause determination. There was insufficient evidence that police training was inadequate. The court denied summary judgment based on a qualified immunity defense. The Sixth Circuit affirmed. View "S.L. v. Pierce Twp. Bd. of Trustees" on Justia Law

The Jefferson Davis County Youth Court held J.P. (minor) in a juvenile detention facility for 103 days, then in the Jefferson Davis County Jail for thirty days more when J.P. attained age eighteen. J.P. was never adjudicated delinquent. No hearing was held on the question of his delinquency. After more than four months in custody, he was released. The court nevertheless ordered his parents to pay the nearly $10,000 cost of J.P.'s 103-day confinement in juvenile detention. On appeal, the Supreme Court reversed the judgment of the youth court and rendered judgment in favor of the parents: the State cannot charge the parents of a minor for his detention when that detention was never legally justified. View "In the Interest of J.P. a Minor: R.P. and D.O. v. Mississippi" on Justia Law

The People filed a petition alleging that petitioner, who had recently turned 13 years old, committed assault with a deadly weapon and assault by means likely to produce great bodily injury. Petitioner denied the allegations and the juvenile court released him to his mother. Petitioner subsequently filed a petition for a writ of mandate to compel the juvenile court to vacate its order finding him competent to stand trial. The court found that the juvenile court applied the standard of competency applicable to adults under Penal Code sections 1367 and 1368, rather than the standard of competency applicable to minors under Welfare and Institutions Code section 709. The juvenile court also made no finding, by a preponderance of the evidence or otherwise, regarding petitioner's ability to consult with counsel and assist in preparing his defense. Accordingly, the court granted the petition and vacated the juvenile court's order finding petitioner mentally competent. View "Bryan E. v. Super. Ct." on Justia Law

The county court for Madison County, sitting as a juvenile court, committed thirteen-year-old Nathaniel to a youth rehabilitation and treatment center. The Nebraska Department of Health and Human Services appealed, arguing that the court did not have the authority under Neb. Rev. Stat. 43-286(1)(b)(i) to commit the juvenile when he was under the age of fourteen. Nathaniel was discharged from the rehabilitation and treatment center after the appeals were filed, causing the appeals to become moot. Acknowledging that the cases were moot, the Department asked the Supreme Court to decide them under the public interest exception to the doctrine of mootness. The Supreme Court declined to do so and dismissed the appeals, holding that, based on the manner in which the cases became moot and the possibility that the issue presented was one of last impression, the public exception to the mootness doctrine did not apply. View "In re Interest of Nathaniel M." on Justia Law