Justia Juvenile Law Opinion Summaries

In an interlocutory appeal, the State appealed a trial court order that suppressed statements defendant-appellee N.A.S. made to police. The trial court found that N.A.S. was in custody when he made the statements, he did not waive his Miranda rights "knowingly, voluntarily or intelligently," and that the statements were involuntary. Upon review, the Supreme Court concluded that in the totality of the circumstances of this case, N.A.S. was not in custody when he made his statements, and that he spoke voluntarily. Accordingly, the Court reversed the trial court's suppression order and remanded the case for further proceedings. View "Colorado v. N.A.S." on Justia Law

The girl, then 15, was charged with misdemeanor battery for allegedly striking a female classmate in the face and chest. A prosecution offer to recommend a continuance under supervision in return for a guilty plea was rejected and the case proceeded to trial. The victim and a security guard who had intervened testified. The accused minor testified that she had acted in self-defense. The trial judge entered a finding of guilt. The probation officer and the prosecution recommended probation, but defense counsel asked for a continuance under supervision. The judge said that the Juvenile Court Act precludes supervision for minors without the permission of the State’s Attorney, that the “approval provision” does not apply in the adult criminal system, and that the approval provision unconstitutional. The judge placed the minor on supervision, over the state’s objection. The Illinois Supreme Court reversed the supervision order as void and vacated the finding of unconstitutionality. The Juvenile Court Act has been interpreted to require that the possibility of supervision be considered before proceeding to a finding of guilt and adjudication as to delinquency. Here, supervision was not requested before the finding of guilt, so any objection by the prosecutor had become irrelevant. The minor lacked standing to raise the constitutional issue. The girl claimed ineffective assistance of counsel because she did not know she was giving up the opportunity for supervision by rejecting the plea offer, and that neither her attorney nor the court knew that supervision had to be requested before a finding of guilt. The court found that the minor had been prejudiced and remanded to allow her to request supervision at the appropriate time. Should the state object, a challenge to the validity of the approval provision could properly be raised.View "In re: Danielle J" on Justia Law

In 2010, two Fare Enforcement Officers entered a train car at the Rainier Beach station and instructed all passengers to present proof of fare. When FEO Willet asked fifteen-year-old K.L.B. and his two companions to present proof of fare payment, they gave him their bus transfers. FEO Willet informed them that while bus transfers used to be valid on the light-rail, they were no longer accepted. The three young males were instructed by FEO Willet to exit the train at the next station. The FEOs asked the three males for identification once they exited the train. All three were either unable or unwilling to provide identification. K.L.B. was temporarily detained at the Othello station. The King County Sheriff's Office was called to assist in identifying K.L.B. and his companions so they could potentially be cited for fare evasion. Deputy Adams then asked K.L.B. to identify one of his male companions. He responded that he did not know his companion's full name and that he: knew him only as '"Marty."' Deputy Adams returned to the station and used a computer database to identify "Marty." There was an assault warrant out for "Marty's" arrest. K.L.B. was charged with two counts of making a false or misleading statement to a public servant under RCW 9A.76. 175. K.L.B. was found guilty of making a false statement to FEO Willet (count II). He was found not guilty of making a false statement to Deputy Adams (count I). K.L.B. appealed to Division One of the Court of Appeals, which affirmed his conviction. K.L.B. argued that a Sound Transit FEO was not a "public servant" as defined in RCW 9A.04.110(23). He also argued that the definition of "public servant" was unconstitutionally vague and that to convict a person of making a false or misleading statement to a public servant, the State must prove that the defendant knew the statement was made to a public servant. The Court of Appeals affirmed the trial court's conclusion that under the statute, FEO Willet was a public servant at the time K.L.B. made the false statement. The Supreme Court held that under these circumstances, because FEOs are not government employees, are not officers of government, and do not perform a governmental function, they are not "public servants" as defined by the statute. View "Washington v. K.L.B." on Justia Law

Petitioner, a juvenile, was arrested and charged with aggravated battery on a victim whom Petitioner knew or should have known was pregnant. Petitioner was on probation at the time of her arrest. Prior to the adjudicatory hearing, it was determined that Petitioner's risk assessment score on her risk assessment instrument (RAI) should be zero. The trial court then placed Petitioner in home detention. Petitioner filed a petition for a writ of habeas corpus, arguing that because her risk assessment score was zero, the trial court could not place her in home detention. Petitioner did not submit a copy of her RAI with her petition. The court of appeal found (1) Petitioner was not required to submit the RAI to properly consider the petition, and (2) because Petitioner's RAI score was zero, the trial court erred in placing her in home detention. The Supreme Court quashed the court of appeal's decision, holding (1) a district court may not grant a juvenile's pre-adjudicatory habeas petition when the court is not presented with the juvenile's RAI; and (2) a juvenile may be placed in home detention with a risk assessment score of zero when the juvenile qualifies for home detention under the specific terms of the RAI. View "State v. S.M." on Justia Law

Anthony Geltz was prosecuted as a juvenile and adjudicated delinquent for sexual abuse in the second degree for an offense he committed when he was fourteen years old. After Geltz turned eighteen, the State petitioned to have him declared a sexually violent predator (SVP) under Iowa Code 229A.2(11). The district court ordered Geltz confined as an SVP based on Geltz's previous offense. The Supreme Court reversed, holding (1) a juvenile adjudication does not constitute a predicate conviction required to commit an offender as an SVP pursuant to section 229A.2; and (2) therefore, the district court erred in committing Geltz as an SVP solely on the basis of his juvenile adjudication for the offense he committed at age fourteen.View "In re Detention of Geltz" on Justia Law

Luis M., a juvenile, admitted that he had committed felony vandalism. The offense involved nine acts of graffiti at six locations. The juvenile court ordered restitution in the amount of $3,881.88, which was a crime prevention officer’s estimation of the amount the City spent to abate Luis’s acts of graffiti in 2011. The court of appeal directed the juvenile court to vacate its restitution order and to hold a new restitution hearing. The Supreme Court affirmed, holding that the juvenile court’s award was not based on sufficient evidence that the amount of claimed loss was a result of Luis’s conduct. View "Luis M. v. Superior Court" on Justia Law

The day after N’s birth, the baby’s mother, Nichole, and her boyfriend, Alfred, executed a voluntary acknowledgement of paternity (VAP), expressly imposing responsibility on Alfred to provide financial support. The VAP did not grant Alfred a right to custody or visitation, but it did provide him the right to seek custody or visitation. Alfred was also entitled to notices of adoption proceedings. Both Nichole and Alfred had the right to rescind the VAP within 60 days. The VAP explicitly waived Alfred’s right to genetic testing. Three days later, the Department of Children and Family Services (DCFS) took N into protective custody. DCFS filed a petition alleging juvenile neglect, identifying Nichole as N’s mother and Alfred as N’s father. The circuit court entered an order for temporary shelter care, placed N in the custody of DCFS, appointed a guardian ad litem (GAL), entered an order identifying Alfred as the “legal” father based on the VAP, and appointed separate counsel for Nichole and Alfred. Following genetic testing, the court granted the state’s motion and dismissed Alfred, based on evidence that he is not N’s biological father. The appellate court reversed, holding that the state did not have standing in a juvenile neglect proceeding (705 ILCS 405/1-1) to challenge the paternity of a man who signed a VAP under the Illinois Parentage Act of 1984 (750 ILCS 45/1). The Illinois Supreme Court affirmed. View "In re N.C., a Minor" on Justia Law

The State charged Petitioner with two counts of first-degree murder and associated offenses. The State filed a motion in the juvenile court seeking to unseal and release Petitioner's juvenile records to assist in the prosecution. The juvenile court issued an order broadly unsealing and releasing the records for "use in the prosecution." The Supreme Court granted Petitioner's petition for extraordinary relief, holding (1) a district attorney is not statutorily authorized to inspect a defendant's sealed juvenile records to obtain information that will be used against him or her in a subsequent proceeding; and (2) therefore, the juvenile court manifestly abused its discretion by granting the State's motion to inspect Petitioner's sealed juvenile records.View "Clay v. Eighth Judicial Dist. Court" on Justia Law

A delinquency complaint charged Juvenile with one count of possession of a class D substance (marijuana) with intent to distribute. Juvenile filed a motion to dismiss, arguing that the complaint was not supported by probable cause that he intended to distribute the marijuana found in his possession. The juvenile court judge allowed the motion but concluded that he was obliged to arraign Juvenile before dismissing the complaint. The Supreme Court affirmed, holding (1) the information in the complaint fell short of probable cause to believe Juvenile intended to distribute the marijuana in his possession; and (2) a juvenile court judge may allow a motion to dismiss before the arraignment of a juvenile where the judge concludes that prearraignment dismissal is in the best interests of the child and the interests of justice.View "Commonwealth v. Humberto H." on Justia Law

Marshall pled guilty to receiving child pornography (18 U.S.C. 2252(a) and (b)) from the time he was 15 until he was 20 years old. The district court varied downward from the guideline range and sentenced him to five years in prison, the mandatory minimum sentence for the offense, expressing concerns about the perceived harshness of that sentence. Marshall has a rare physiological condition, Human Growth Hormone Deficiency, which he believes entitles him to the Eighth Amendment protections accorded to juveniles. Although diagnosed with an I.Q. score of 87 and a mental age of 15, Marshall attended a community college part-time for four semesters, pursuing a career as a lab technician and paying his own tuition. He worked as a machine operator for a commercial bakery. He owned a car and had a credit card. He claimed that he felt like he was viewing images of his peers and that he often felt like a 15 or 16-year-old individual because of his small frame and stature. The Sixth Circuit affirmed, stating that Marshall was an adult at the time of his crimes.View "United States v. Marshall" on Justia Law