Justia Juvenile Law Opinion Summaries

Minor Zachary Stringer was charged with the murder of his younger brother, Justin. The jury found Zachary guilty of the lesser-included offense of manslaughter. The trial court sentenced Zachary to twenty years, with ten years to serve and ten years of post-release supervision, with five years reporting. Zachary appealed his conviction and sentence, arguing: (1) the trial court erred by allowing multiple gruesome photographs of the victim and the crime scene into evidence; and (2) the trial court erred in denying his motion for judgment notwithstanding the verdict (JNOV). Finding no error, the Supreme Court affirmed Zachary's conviction and sentence.View "Stringer v. Mississippi" on Justia Law

The State charged appellant "Kevin R." with possessing a weapon on school grounds. Prior to his adjudicatory hearing before a family court judge, Appellant moved for a jury trial on the grounds the federal and state Constitutions guaranteed him the right to a jury trial. The judge denied the motion and proceeded to hear Appellant's case in a bench trial. Ultimately, the judge adjudicated Appellant delinquent and deferred sentencing until an evaluation of Appellant was completed. The sentencing hearing was conducted before a second family court judge, who sentenced Appellant to an indeterminate period of time not to exceed his twenty- first birthday. The judge then suspended the sentence and placed Appellant on probation until his eighteenth birthday. On appeal, Appellant contended the family court judge erred in denying his motion for a jury trial. Recently, the South Carolina Supreme Court held a juvenile did not have a constitutional right to a jury trial in adjudication proceedings. However, the Court's decision in that case was not dispositive as it was presented with additional arguments raised by Appellant and the Amici Curiae. After consideration of these issues, the Court adhered to its decision in the earlier case, and affirmed the family court. View "In the Interest of Kevin R." on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court.View "Idaho v. John Doe (2012-10)" on Justia Law

Father appealed the juvenile court's order removing his three-year-old daughter from his custody for a single occasion of disciplining her by spanking her with a belt on her legs and buttocks. The court concluded that, given all the circumstances, the evidence with respect to the risk of harm to the child if Father were allowed back to the home, does not satisfy the requisite "clear and convincing" standard of proof. Further, there may be less drastic alternatives than an order requiring Father to leave the home. Accordingly, the court reversed the order to the extent it requires Father to remain outside the home and otherwise affirmed the remaining findings. View "In re A.E." on Justia Law

The trial court concluded that section 5-615 of the Juvenile Court Act, 705 ILCS 405/5-615, was unconstitutional, and ordered a continuance under supervision in a case involving a minor, rejecting a negotiated plea agreement. The minor had been the subject of multiple charges and had failed to appear for court dates. The Illinois Supreme court vacated. The provision at issue grants a State’s Attorney, among others, authority to object to the entry of an order of continuance under supervision in a juvenile case before a finding of guilt. The court noted that juvenile proceedings are fundamentally different from criminal proceedings, a difference which extends to the role of the state. The purposes and objectives of the Juvenile Court Act are protective in nature, to correct and rehabilitate, not to punish, and the Act lists the State’s Attorney among those who would undoubtedly be concerned with the children’s best interests. The State’s Attorney has a duty to see that justice is done not only to the public at large, but to the accused as well. In this case, the state exercised its authority under section 5-615 in accordance with that duty.View "In re Derrico G." on Justia Law

Mother appealed the juvenile dependency court's jurisdictional orders based on its findings that Mother has a history of substance abuse which renders her incapable of providing her teenage daughter with regular care and supervision. The dependency court further found that Mother's drug abuse endangered her daughter's health and safety, and places her daughter at risk of physical harm. The court concluded that substantial evidence supported the dependency court's finding that Mother suffers from a substance problem. The court concluded, however, that the evidence does not support the dependency court's finding that her substance abuse has caused or is causing a substantial risk of harm to the daughter. Accordingly, the court reversed the dependency court's orders. View "In re Rebecca C." on Justia Law

Defendant was convicted of first degree murder and sentenced to life imprisonment for a murder he committed when he was sixteen years old. More than fifteen years later, Defendant filed an amended postconviction motion challenging his life imprisonment sentence. The district court denied the motion. After Defendant appealed, the U.S. Supreme Court decided Miller v. Alabama, which held that the Eighth Amendment forbids a state sentencing scheme that mandates life in prison without the possibility of parole for a juvenile offender convicted of homicide. The Supreme Court reversed in this case, holding (1) the rule announced in Miller applied retroactively to Defendant; and (2) Defendant’s sentence was unconstitutional under Miller, and therefore, Defendant was entitled to be resentenced. Remanded. View "State v. Mantich" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree felony murder and other charges arising from three shootings. At the time of the shootings, Defendant was fifteen years old. Defendant was sentenced to two life terms without the possibility of parole for the murder counts. The Supreme Court affirmed Defendant’s convictions in all respects but vacated the sentences of life imprisonment without the possibility of parole, holding that the life imprisonment sentences were unconstitutional under Miller v. Alabama, in which the U.S. Supreme Court held that it is unconstitutional to sentence a juvenile convicted of a homicide to a mandatory sentence of life imprisonment without the possibility of parole.View "State v. Castaneda" on Justia Law

Juvenile Trevor G. was arraigned on a delinquency petition alleging he had endangered the welfare of a minor. He moved to dismiss the petition because none of the State's witnesses against him were present, and therefore the State could not proceed with its case. The State acknowledged none of its witnesses were present and did not object to the motion, but requested leave to file for reconsideration if it learned there was a good reason why its witnesses did not show. The case was dismissed for lack of prosecution, and the State did not move for reconsideration. A few months later, the State refiled its petition. Trevor moved to dismiss, arguing that the adjudicatory hearing was outside the statutory time limit. The court again held a hearing, and again the witnesses did not show. The Court denied Trevor's motion, finding that because Trevor initiated the dismissal, the State was not barred from re-filing. The Supreme Court granted the trial court's request for interlocutory appeal. The issue before the Court was whether the trial court erred in its conclusion that the statutory time limits for the State to re-file its delinquency petition for lack of prosecution was not violated because the dismissal was initiated by the juvenile. The Supreme Court concluded that the trial court erred in its interpretation, and reversed the order denying Trevor's motion to dismiss. View "In re Trevor G." on Justia Law

Responding to a report of underage drinking in a home, officers found a group celebrating eighth grade graduation. Police asked the teens to step outside individually for breathalyzer testing. Seven tested positive for alcohol. Police arrested them and notified their parents. In the morning, a juvenile worker arrived at the police station, and, after speaking with a judge, indicated that the children were to be detained for a court appearance the next day. At the regional juvenile detention center, the minors underwent routine fingerprinting, mug shots, and metal-detection screening. During a hygiene inspection and health screening, they were required to disrobe completely for visual inspection to detect “injuries, physical abnormalities, scars and body markings, ectoparasites, and general physical condition.” A same-sex youth worker observed the juveniles for several minutes from a distance of one to two feet, recording findings for review by an R.N. The minors were required to shower with delousing shampoo. They were released the following day. The charges were dropped. In a suit under 42 U.S.C. 1983, the district court granted partial summary judgment in favor of the juveniles, based on a “clearly established right for both adults and juveniles to be free from strip searches absent individualized suspicion” that negated a qualified immunity defense. The Sixth Circuit reversed, stating that no clearly established principle of constitutional law forbids a juvenile detention center from implementing a generally applicable, suspicionless strip-search policy upon intake into the facility.View "T. S. v. Doe" on Justia Law