Justia Juvenile Law Opinion Summaries

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

Police officers were dispatched in response to reports of an armed subject pointing a rifle at several people from the window of a light beige or tan vehicle. After Defendant Leticia T. (Child) and children passengers were removed and detained, the officers conducted a warrantless search of the interior and trunk of the vehicle. The district court held that the warrantless search was justified by exigent circumstances. The Court of Appeals reversed the district court, ruling that the possibility of a person hiding in the trunk of a vehicle did not constitute exigency. The issue on appeal to the Supreme Court centered on the Court of Appeals' reversal. The Supreme Court conclude after a review of the district court record was that when police officers have probable cause and exigent circumstances to believe that an armed subject pointed a rifle at other individuals from a vehicle, officers may search the cab and the trunk of that same vehicle for the rifle. View "New Mexico v. Leticia T." on Justia Law

After J.S., a juvenile, injured an individual with a knife, the state police filed two petitions against J.S., including a petition alleging that J.S. was delinquent due to having committed an offense that, if committed by an adult, would constitute an assault with a dangerous weapon. The family court found J.S. delinquent for committing an assault with a dangerous weapon and placed him on probation. The Supreme Court affirmed, holding that there was sufficient legally competent evidence to support (1) the trial justice’s finding that the State presented sufficient evidence to disprove J.S.’s defense of self-defense beyond a reasonable doubt, and (2) the trial justice’s adjudication of Respondent as delinquent for having committed an assault with a dangerous weapon. View "In re J.S." on Justia Law

When she was sixteen years old A.J.M. was adjudicated delinquent by the juvenile court. The delinquency was based on the crime of sexual abuse in the second degree, an offense covered under the sex offender registry statute. The juvenile court opted to wait to decide whether A.J.M. should be required to register as a sex offender until she successfully completed sexual offender treatment. After a final review hearing, the juvenile court discharged A.J.M. and waived the requirement for her to register as a sex offender, concluding that A.J.M.’s failure to overcome her problems was the fault of the State. The Supreme Court affirmed the decision of the juvenile court to discharge A.J.M. but concluded that the record was not sufficient for the Court to properly review the juvenile court’s exercise of discretion to waive the requirement for A.J.M. to register as a sex offender. Remanded. View "In re Interest of A.J.M." on Justia Law

When Respondent was fifteen, he was charged with unlawful possession of weapons by persons under sixteen in violation of N.Y. Penal Law 265.05. The charges stemmed from a police officer’s recovery of a machete from Respondent. The Appellate Division found the petition facially insufficient because it did not contain allegations that would have established that the knife Respondent possessed was a “dangerous knife” under section 265.05. Rather, the Appellate Court found that the knife was “utilitarian.” The Court of Appeals reversed, holding that, “while a machete has utilitarian purposes, it would be unreasonable to infer from the statement supporting the petition that Respondent was using the machete for cutting plants.” View "In re Antwaine T." on Justia Law

The State petitioned for relief from an in limine ruling of the juvenile court allowing the introduction of testimony by the juvenile’s psychological expert without regard for the court-ordered examination mandated by section 16-8-107, C.R.S. (2013). The juvenile court reasoned that in the absence of any provision of the Criminal Procedure Code specifying otherwise, the requirements of section 16-8-107 did not apply to delinquency proceedings. Finding no error in the juvenile court's analysis, the Supreme Court affirmed. View "Colorado in the Interest of A.A." on Justia Law

When E.G. was fifteen years old, the Youth Court found him to be delinquent and ordered that he be committed to the Department of Corrections until age eighteen. After remand, the Youth Court stated that it would retain jurisdiction until E.G. was twenty-one and consider transfer of the case to the district court. When E.G. turned eighteen, the Youth Court, after a hearing, transferred supervision of E.G. to the district court. E.G. subsequently violated his probation, and the district court sentenced him to the Department of Corrections until age twenty-five. E.G. appealed, arguing that the district court lacked jurisdiction to revoke his probation and sentence because his parents did not receive notice of the hearing on the State’s motion to transfer supervision of his probation from the Youth Court to the District Court. The Supreme Court affirmed, holding that the statutory parental notice requirement did not withdraw, circumscribe, limit or affect the Youth Court’s jurisdiction over the issue of transferring supervision of E.G. to the District Court. View "In re E.G." on Justia Law

Plaintiff-Appellee Brandon Blackmon brought a 42 U.S.C. 1982 action against various members of the juvenile detention center in Sedgwick, Kansas, alleging they violated his Fourteenth Amendment rights as a pre-trial detainee when he was taken there as an eleven-year-old. He claimed that the staff regularly used a "Pro-Straint Restraining Chair, Violent Prisoner Model" sometimes as a legitimate effort to stop him from committing suicide, but mostly, as plaintiff contended, to punish him. The chair is equipped with wrist, chest and ankle restraints; as a juvenile detainee, plaintiff was 4'11' and 96 pounds. The district court denied defendants' motion for dismissal based on qualified immunity grounds. Defendants appealed to the Tenth Circuit, maintaining that the district court erred in holding that the facts, when viewed in a light favorable to plaintiff, suggested that defendants sometimes exceeded the scope of qualified immunity. After its review of the district court record, the Tenth Circuit affirmed in all respects except one: the Court directed the district court to grant qualified immunity to defendant Sutton on plaintiff's "failure to transfer" claim.View "Blackmon v. Sutton, et al" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown, robbed two victims in their home. The victims were killed during the robbery. Brown was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Brown to an aggregate sentence of 150 years, the same sentence imposed on Brown’s cohorts. The Supreme Court revised the 150-year sentence received by Brown, holding that Brown’s sentence “foreswears altogether the rehabilitative ideal,” and concluded that Brown should be sentenced to an enhanced sentence to a total aggregate sentence of eighty years imprisonment. View "Brown v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown and fifteen-year-old Defendant, robbed two victims in their home. The victims were killed during the robbery. Defendant was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Defendant to an aggregate sentence of 150 years, the same sentence imposed on Brown. The Supreme Court revised the 150-year sentence received by Brown and similarly exercised its constitutional authority to revise Defendant’s sentence, holding that Defendant’s sentence “foreswears altogether the rehabilitative ideal” and concluding that Defendant should total aggregate sentence of eight-five years imprisonment. View "Fuller v. State" on Justia Law