Justia Juvenile Law Opinion Summaries

Petitioner was convicted of first degree murder when she was 16 years old for her part in the murder of her boyfriend. Petitioner appealed the district court's dismissal of three claims in her federal habeas petition as untimely under the one-year statute of limitations set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(d)(1). Because the court applied the AEDPA statute of limitations on a claim-by-claim basis, and because petitioner's three claims challenging a state administrative agency's order were filed nearly 18 months after the statute of limitations expired, the court affirmed the district court's dismissal. View "Mardesich v. Cate, et al." on Justia Law

K.H. appealed juvenile court order that extended the placement of his daughter T.H. in the custody and control of Barnes County Social Services and an order that denied his motion to dismiss. On appeal, K.H. argued the juvenile court lacked jurisdiction, applied the wrong standard of proof in finding the child was deprived in 2008, erred in allowing his plea to the allegations of deprivation, the duration of the deprivation proceedings was excessive, and in finding the child continues to be deprived. Finding that the juvenile court did not abuse its discretion, the Supreme Court affirmed. View "Interest of T.H." on Justia Law

This case arose from a dependency-neglect proceeding. After a permanency-planning hearing was set, the circuit court discovered that the Department of Human Services (DHS) had failed to draft and put into place a case plan. The court then ordered that, as the case worker had forty-one cases on her caseload and fifty juveniles in fostercare, DHS should rectify the issue in five days. DHS subsequently filed a petition for a writ of certiorari, asserting that the circuit court exceeded its jurisdiction and violated the separation-of-powers doctrine by issuing an order that DHS alleged invaded the discretionary functions of the executive branch. The Supreme Court denied the writ, holding that the circuit court was within its jurisdiction to act to protect the integrity of the proceedings and to safeguard the rights of the litigants before it when it ordered DHS to correct problems that were preventing work and services. View "Ark. Dep't of Human Servs. v. Shelby" on Justia Law

Defendant appealed from a Family Court sentencing order initially entered when he was a juvenile where he robbed a woman with a BB gun. Defendant contended that the Family Court did not have the authority to sentence him, at the outset, to twelve months of adult probation following his juvenile commitment. Because the statute the Family Court relied upon affirmatively provided only two circumstances, not present in this case, where the Family Court could sentence a juvenile to adult probation, the court found that the General Assembly intended to limit the authority of the Family Court to impose adult consequences on the juvenile. Accordingly, the court reversed and remanded for a correction of the sentence order. View "Brown v. State" on Justia Law

Defendant was indicted in superior court for armed robbery and other offenses even though he was 16 years old at the time of the alleged crimes. Defendant moved to transfer the case to juvenile court. Although the superior court found that no money was actually physically removed from the cash register, the trial court denied the motion to transfer, concluding that a taking and thus an armed robbery had occurred. The Court of Appeals affirmed. The court held that the Court of Appeals correctly affirmed the superior court's denial of the motion to transfer where the single act of pulling a cash drawer out from the register constituted the requisite change of location. View "Gutierrez, et al. v. Holder, Jr." on Justia Law

In this juvenile delinquency case, the prosecution filed an interlocutory appeal seeking the Supreme Court's review of a magistrate's order suppressing certain statements made by the juvenile during a police interrogation. Because the magistrate's suppression order was never reviewed and adopted (with or without modification) by the district court before the appeal was filed, the Supreme Court lacked appellate jurisdiction, and accordingly dismissed the appeal. View "Colorado v. S.X.G." on Justia Law

Defendant, a juvenile, was charged in a complaint with being a delinquent child for breaking and entering a motor vehicle in the nighttime, with the intent to commit a felony. At issue was whether G.L.c. 119, section 58, empowered a Juvenile Court judge to continue a delinquency case without a finding and place the juvenile under the supervision of the probation department, notwithstanding a jury's prior verdict of delinquency. Based on the text of the statute, its placement within the broader statutory scheme, and the underlying philosophy of the juvenile justice system, the court concluded that it did. Accordingly, the case was remanded to the county court, where an order shall enter affirming the Juvenile Court judge's order. View "Commonwealth v. Magnus M." on Justia Law

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute. View "In re M.L.M." on Justia Law

Three juvenile defendants, each of whom was a member of an Indian Tribe and who pleaded true to a charge of aggravated sexual abuse with children, appealed their conditions of probation or supervision requiring registration under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901, et seq. Defendants argued that SORNA's registration requirement contravened the confidentiality provisions of the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031 et seq., and also challenged its constitutionality. The court held that because Congress, in enacting SORNA, intentionally carved out a class of juveniles from the FJDA's confidentiality provisions, and that SORNA's registration requirement was constitutionally sound, the district court's imposition of the sex offender registration conditions was constitutionally sound. View "United States v. Juvenile Male" on Justia Law

A juvenile male appealed the district court's determination that he was an "Indian" under 18 U.S.C. 1153, which provided federal criminal jurisdiction for certain crimes committed by Indians in Indian country. The juvenile claimed that he did not identify as an Indian, and was not socially recognized as Indian by other tribal members. Nonetheless, he was an enrolled tribal member, had received tribal assistance, and had used his membership to obtain tribal benefits. Therefore, because the juvenile was Indian by blood and easily met three of the most important factors used to evaluate tribal recognition laid out in United States v. Bruce, the court held that he was an "Indian" under section 1153 and upheld his conviction. View "United States v. Juvenile Male" on Justia Law