Justia Juvenile Law Opinion Summaries

The juvenile court took jurisdiction over A.J.C. for conduct that, if committed by an adult, would have constituted possession of a firearm in a public building, unlawful possession of a firearm, unlawful use of a weapon, and menacing. The question this case presented to the Supreme Court for review was whether the school-safety exception to the warrant requirement announced in "State ex rel Juv. Dept. v. M. A. D.," (233 P3d 437 (2010)), permitted a school principal to conduct a warrantless search of the youth’s backpack after the principal had seized the backpack from the youth. The juvenile court concluded that the search was permissible under the school-safety exception, and it denied youth’s pretrial motion to suppress. The Court of Appeals affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Oregon v. A. J. C." on Justia Law

The issue before the Supreme Court in this case centered on whether "Miller v. Alabama," (567 U.S. __ (2012)) applied retroactively in state collateral proceedings. Defendant Darryl Tate, whose mandatory life-without-parole sentence for a second-degree murder he committed as a juvenile became final in 1984, filed a motion seeking resentencing in light of Miller. The District Court denied his motion, but the Court of Appeal granted writs, remanding the matter for a sentencing hearing. The Louisiana Supreme Court granted writs to address the retroactivity of Miller to those juvenile homicide convictions final at the time Miller was rendered. Upon review, the Louisiana Court found Miller did not apply retroactively in cases on collateral review as it merely set forth a new rule of criminal constitutional procedure, which is neither substantive nor implicative of the fundamental fairness and accuracy of criminal proceedings. Therefore, the Court reversed the judgment of the Court of Appeal and reinstated the judgment of the District Court.View "Louisiana v. Tate" on Justia Law

The Youth Court declared A.S.M. a delinquent youth and serious juvenile offender. The Youth Court later issued an order under Mont. Code Ann. 41-5-208 ("section 208 order") transferring jurisdiction over A.S.M. to the district court and transferring supervisory responsibility of A.S.M. to the Department of Corrections (DOC). Pursuant to the order, A.S.M. was transferred to to Montana State Prison (MSP) on his eighteenth birthday and was not eligible for parole until he completed MSP’s sexual offender program. A.S.M. filed a motion to modify the order, requesting that the DOC send him to Whitney Academy in Massachusetts. The district court partially modified the section 208 order to remove the parole eligibility requirement but refused further to modify the order, thus keeping A.S.M. in the adult corrections system. A.S.M. appealed, requesting that the district court modify its order to facilitate his placement at the Academy by suspending his sentence and terminating supervision by the DOC. The Supreme Court affirmed, holding that the district court did not err by refusing to further modify the section 208 order. View "In re A.S.M." on Justia Law

The Supreme Court granted allocatur in this case to decide “whether and when a reviewing court considering a challenge to a pretrial ruling, whether in a post-verdict or appellate context, may look beyond the record of evidence presented at the suppression hearing.” The Superior Court relied on a footnote from the Court's decision in "Commonwealth v. Chacko," (459 A.2d 311 (Pa. 1983)), for the proposition that “it [was] appropriate to consider all of the testimony, not just the testimony presented at the suppression hearing, in determining whether evidence was properly admitted.” The Superior Court, (pursuant to "Chacko") considered evidence adduced for the first time at trial when deciding whether the police properly seized contraband from Appellant, L.J. Specifically, the court affirmed the trial court’s denial of suppression because trial testimony established that L.J. voluntarily consented to the search at issue. Upon review of the record, the Supreme Court found that the Superior Court’s reliance on Chacko was understandable but ultimately misplaced. Accordingly, the Court vacated the disposition order, and remanded this case to the juvenile court for a new suppression hearing. View "In the Interest of: L.J." on Justia Law

Brandon, then 14 years old, was charged by petition for adjudication of wardship with aggravated criminal sexual abuse of his cousin M.J., then three years old, 720 ILCS 5/12-16(c)(2)(i).” M.J. was unable to testify. The state gave notice and offered statements that M.J. made to her mother and to Detective Hogren, of the Danville police department that “Brandon put that stuff in his mouth on her vagina which made her vagina hurt and Brandon put his finger in her vagina” and that “Brandon put his finger in her vagina which made her feel bad and Brandon spit on her vagina and put his penis on her at Uncle Mike’s.” Following an adjudicatory hearing, the circuit court found him guilty and sentenced him to the Illinois Department of Juvenile Justice for an indeterminate period not to exceed the period for which an adult could be committed for the same act, or the date of his twenty-first birthday, whichever came first. The appellate court affirmed. The Illinois Supreme Court affirmed, holding that error in admitting Detective Hogren’s hearsay testimony was cumulative of "overwhelming' properly admitted testimonial evidence and did not contribute to the adjudication of guilt.View "In re Brandon P." on Justia Law

Bingham, then in her late teens, committed aggressive acts toward adults and children, including grabbing and kissing. She was declared a sexually dangerous person under the Sexually Dangerous Persons Act, 725 ILCS 205/1.01. The Director of the Illinois Department of Corrections was appointed as her guardian. She was to remain committed “until or unless [she] is recovered and released.” The appellate court reversed. The Illinois Supreme Court affirmed. The limited evidence was insufficient to establish that it was substantially probable that Bingham would commit future sex offenses. A single incident, in which she attempted to grab a woman’s breast area through her shirt, was insufficient to establish that substantial probability. Another incident, involving Bingham touching the buttocks of 17-year-old Katie C, was not clearly intentional; Katie C. acknowledged that Bingham only touched her one time and stopped as soon as Katie C. asked her to do so. There was no evidence that the incident was done as a result of “arousal or gratification of sexual needs or desires.” Without evidence of either an act of sexual assault or acts of child molestation, the state failed to prove propensities toward acts of sexual assault or sexual molestation of children.View "People v. Bingham" on Justia Law

In 2001, the Bryan family’s adopted son, J.O., repeatedly raped and molested his younger foster brother, K.B., in the room the boys shared. After weeks of abuse, K.B. told his foster parents, who contacted the Erie County Office of Children and Youth (ECOCY), which had facilitated J.O.’s adoption, and had J.O. removed from their home. The Bryans blamed ECOCY for K.B.’s ordeal, claiming that ECOCY employees concealed J.O.’s history of violent behavior and sexual misconduct. The Bryans sued ECOCY and seven employees under 42 U.S.C. 1983 on a theory that permits recovery from state actors when “the state’s own actions create the very danger that causes the plaintiff’s injury.” During trial, the parties agreed to a high-low settlement. Regardless of the verdict, the Bryan family was to receive at least $900,000 and defendants were to pay no more than $2.7 million. The jury returned an $8.6 million verdict; the defendants tendered $2.7 million. The Bryans claimed breach of the settlement agreement’s confidentiality clause, rendering the deal unenforceable. The district court concluded that it lacked subject matter jurisdiction to decide whether to enforce those terms or the verdict. The Third Circuit remanded. The case was not dismissed, nor was the verdict satisfied. A district court’s jurisdiction does not terminate at the moment jury deliberations do. View "Bryan v. Erie Cnty. Office of Children & Youth" on Justia Law

In 1999, Appellant, his codefendant, and two accomplices robbed the occupants of a vehicle at gunpoint. In the course of the robbery, Appellant shot and killed the victim. At the time, Appellant was seventeen years of age. In 2002, Appellant was convicted of second-degree murder and related offenses. He received a mandatory sentence of life imprisonment without the possibility of parole, plus a term of imprisonment. On direct appeal, the Superior Court affirmed; the Supreme Court denied Appellant’s petition for allowance of appeal; and Appellant did not seek discretionary review in the United States Supreme Court. Appellant then timely filed a post-conviction petition claiming, inter alia, that the life-without-parole sentence violated his rights under the Eighth Amendment to the United States Constitution, as extended to the States via the Fourteenth Amendment. Specifically, the issue before the Pennsylvania Supreme Court in this case was whether “Miller v. Alabama,” (132 S. Ct. 2455 (2012)) applied retroactively to Appellant’s 2002 judgment of sentence, which became final in 2005. The United States Supreme Court issued the Miller decision in June 2012, rendering Pennsylvania’s mandatory scheme of life imprisonment for first- and second-degree murder unconstitutional, as applied to offenders under the age of eighteen at the time of their crimes. Significantly, as pertaining to this case, the Miller majority did not specifically address the question of whether its holding applied to judgments of sentence for prisoners, such as Appellant, which already were final as of the time of the decision. The Pennsylvania Court applied settled principles of appellate review, and found nothing in Appellant’s arguments persuaded it that Miller’s proscription of the imposition of mandatory life-without-parole sentences upon offenders under the age of eighteen at the time their crimes were committed must be extended to those whose judgments of sentence were final as of the time of Miller’s announcement. View "Pennsylvania v. Cunningham" on Justia Law

A.S. was sentenced as an aggravated juvenile offender to two years' commitment to the Department of Human Services, suspended on condition of successful completion of two years' probation. The district court vacated the sentence and remanded for resentencing, holding that 19-2-601 C.R.S. (2013) authorized only commitment to DHS, and did not grant a court discretion to grant probation. Upon review of the applicable statute, the Supreme Court concluded 19-2-601 does indeed grant a sentencing court discretion. View "A.S. v. Colorado" on Justia Law

Korsiba Arot was charged in district court with three counts of gross sexual imposition for incidents that occurred in the summer of 2011, the latest of which occurred in August, 2011. Arot moved to dismiss the criminal charges arguing the court lacked jurisdiction to hear the case because Arot was not eighteen at the time of the incidents. The district court found the State failed to prove by the preponderance of the evidence that Arot was eighteen at the time of the incidents. The charges were dismissed. The State appealed the dismissal of charges. Finding no error in the dismissal, the Supreme Court affirmed. View "North Dakota v. Arot" on Justia Law