Justia Juvenile Law Opinion Summaries
Washington v. Haag
In 1995, petitioner Timothy Haag was sentenced to mandatory life without parole for a crime he committed at the age of 17. In 2018, at a Miller-fix resentencing conducted pursuant to RCW 10.95.030, the resentencing court expressly found that “Haag is not irretrievably depraved nor irreparably corrupt.” Yet the court resentenced Haag to a term of 46 years to life; the earliest that he could be released is at the age of 63. Haag sought review by the Washington Supreme Court, arguing that the trial court erroneously emphasized retribution over mitigation and that his sentence amounted to an unconstitutional de facto life sentence. To this, the Supreme Court agreed, holding the resentencing court erred because it gave undue emphasis to retributive factors over mitigating factors. The Court also held Haag’s 46-year minimum term amounts to an unconstitutional de facto life sentence. Judgment was reversed and the matter remanded for resentencing. View "Washington v. Haag" on Justia Law
Brown v. Precythe
In an action arising from a constitutional challenge to Missouri's remedial parole review process for individuals sentenced to mandatory life without the possibility of parole for homicide offenses committed as juveniles, a class of Missouri inmates who were sentenced to mandatory life without parole for such juvenile homicide offenses filed suit claiming that Missouri's parole review policies and practices violate their rights to be free from cruel and unusual punishment and their rights to due process of law under the U.S. Constitution and the Missouri Constitution. The district court granted summary judgment in favor of plaintiffs.The Eighth Circuit agreed with the district court that Missouri's policies and practices, when implemented and considered in combination, worked to deprive plaintiffs of their Eighth Amendment right to a meaningful opportunity to obtain release based upon demonstrated maturity and rehabilitation. The court explained that, because the parole review process in place under Senate Bill 590 failed to adequately ensure that juveniles whose crimes reflect only transient immaturity—and who have since matured—will not be forced to serve a disproportionate sentence, it violated the Eighth Amendment.The court affirmed the order of the district court determining that the parole review process of SB 590 violated plaintiffs' Eighth Amendment rights, and affirmed the order determining that Missouri cannot use a risk assessment tool in its revised parole proceedings unless it has been developed to address the unique circumstances of the JLWOP Class. The court vacated the order regarding appointment of counsel and remanded for further proceedings. Finally, the court denied plaintiffs' motion to strike. View "Brown v. Precythe" on Justia Law
State v. N.R.
The Supreme Court affirmed the judgment of the court of appeals finding that lifetime registration requirements under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), were not punishment as applied N.R. and therefore did not trigger any constitutional provisions identified by N.R., holding that there was no error.N.R. pled guilty to rape and was adjudicated a juvenile offender. The gestate judge ordered N.R. to register as a sex offender for five years under KORA. Just before N.R.'s registration period was about to expire, the legislature amended KORA. As a result, N.R. was required to register for life. Later, the State charged N.R. for failing to register. N.R. filed a motion to dismiss, arguing that KORA's mandatory lifetime registration requirements for juvenile sex offenders violates the federal and state constitutional provisions against cruel and unusual punishment and the federal constitutional provision against ex post facto punishment. The district court found Defendant guilty. The Supreme Court affirmed, holding that KORA's mandatory lifetime registration requirements as applied to N.R. are not punishment and therefore do not violate the federal Ex Post Facto Clause or the prohibition against cruel and unusual punishment under the Kansas and United States Constitutions. View "State v. N.R." on Justia Law
People v. Moore
The Court of Appeal concluded that Penal Code section 3051, subdivision (h) does not violate equal protection, and the exclusion of offenders sentenced under the Three Strikes law from youth offender parole consideration is rationally related to a legitimate penal interest. The court also concluded that it lacks jurisdiction to rule on appellant's clam that the imposition of the five-year enhancement under Penal Code section 667, subdivision (a) resulted in an unauthorized sentence. Accordingly, the court affirmed the postjudgment order. View "People v. Moore" on Justia Law
S.H.R. v. Rivas
S.H.R. petitioned the superior court for the appointment of a guardian of his person and for judicial findings that would enable him to petition the USCIS to classify him as a special immigrant juvenile (SIJ) under federal immigration law. The superior court denied both petitions.The Court of Appeal concluded that S.H.R. had the burden of proving by a preponderance of the evidence the facts supporting SIJ status. Because the trial court found his evidence did not support the requested findings, S.H.R. has the burden on appeal of showing that he is entitled to the SIJ findings as a matter of law. In this case, S.H.R. has failed to meet his burden by failing to prove parental abandonment or neglect and that reunification was not viable. Therefore, the court affirmed the superior court's denial of the SIJ petition. The denial of the SIJ petition rendered the guardianship petition moot, and thus the court also affirmed the denial of that petition. View "S.H.R. v. Rivas" on Justia Law
In re Moore
Moore was convicted of murder (Penal Code 187) and robbery (section 211); a jury found true the special circumstance that the murder was committed during a robbery (190.2(a)(17)). Moore sought habeas relief, challenging the sufficiency of the evidence for the robbery-murder special-circumstance finding.The California Supreme Court ordered the court of appeal to consider “whether [Moore’s] youth at the time of the offense should be one of the factors considered under” precedent in which the California Supreme Court examined the felony-murder special circumstance, Penal Code 190.2(d). Under that provision, a person who is guilty of murder but is not the “actual killer” and who aids or abets the commission of certain felonies that result in death may be sentenced to death or life without the possibility of parole if that person is a “major participant” and acts with “reckless indifference to human life.”On remand, the court of appeal vacated the conviction. A defendant’s youth at the time of the offense should be a factor in determining whether that defendant acted with reckless indifference to human life under section 190.2(d). Considering the totality of the circumstances, including the fact that Moore was only 16 at the time of his offenses, the court found insufficient evidence to establish that Moore acted with the requisite reckless indifference to human life. View "In re Moore" on Justia Law
In re N.B.
N.B. was removed from her parents’ care in 2008 when she was one year old. Her grandmother, Catherine, cared for her became her legal guardian in 2012. A maternal aunt also became a co-guardian. Years later N.B. struggled with her mental health and Catherine had trouble managing her care. The juvenile court found that N.B. was suffering serious emotional damage. Services were provided. She was released to her maternal aunt’s care after she said she did not feel safe returning to Catherine’s care. The maternal aunt became “overwhelmed” and returned her to Catherine. N.B. continued to suffer mental health issues.A petition under section 388 sought to terminate the guardianship rights of the maternal aunt and the family maintenance services. Catherine and the aunt had lied about N.B.’s whereabouts and well-being, and asked N.B. to lie during home visits. N.B. was placed in a foster home. N.B. “stabilized.” The Agency recommended terminating Catherine’s legal guardianship. Catherine objected.The juvenile court observed that there was not “any doubt on anybody’s part that [Catherine] loves [N.B. and] that she is committed to [N.B.]” but expressed concern that Catherine’s behavior was contributing to N.B.’s problems. The court terminated the legal guardianship of Catherine and the maternal aunt. The court of appeal affirmed, rejecting Catherine’s argument the Agency was required to “follow the procedures and requirements of section 387” to terminate her guardianship. View "In re N.B." on Justia Law
Gomez v. Bennett
The Supreme Court granted Guernsey County Juvenile Court Judge David Bennett's motion to dismiss this habeas corpus action against him and sua sponte dismissed this action as to Muskingum County Juvenile Court Magistrate Erin Welch, holding that the petition was procedurally defective and failed to state a claim for relief.Petitioner filed an amended petition for a writ of habeas corpus on behalf of his minor son, E.G., naming Judge Bennett and Magistrate Welch as respondents and alleging that E.G.'s current detention was illegal. The Supreme Court dismissed the action because (1) the amended petition was defective for failure to satisfy Ohio Rev. Code 2725.04(D); (2) Petitioner failed to name a proper respondent; and (3) Petitioner's amended petition failed to stat a valid claim for habeas relief. View "Gomez v. Bennett" on Justia Law
In re M.W.
When he was 17 years old, M.W. assaulted his girlfriend. After a Welfare and Institutions Code section 602 petition was filed, seeking to have him declared a ward of the juvenile court, M.W. admitted to willful infliction of corporal injury. The juvenile court adjudged M.W. a ward of the court and ordered him to reside in his mother’s home under the probation department’s supervision and to complete a 52-week “Batterer’s Intervention Program” because M.W. had a “pattern of engaging in violent behavior, as well as inappropriateness with females.”M.W. requested that the court order the probation department to pay for the program. M.W. had already enrolled in the program at a cost of $153 per month, approximately $1,800 for the 52-week program. The court denied M.W.’s request. The court of appeal reversed. Under the Welfare and Institutions Code, neither M/W/ nor his mother is liable for the costs of his treatment program. A court may not impose liability on a minor’s parents unless authorized by statute; a minor may be liable for costs only in very limited instances. The People cite no authority to support an order imposing the costs of the Batterer’s Intervention Program on M.W. or his family. View "In re M.W." on Justia Law
Commonwealth v. Sharma
The Supreme Judicial Court vacated the denial of Defendant's Mass. R. Crim. P. 30(a) motion seeking to vacate his remaining sentences after he was paroled from his life sentence for murder and remanded the matter to the superior court for a hearing, holding that the motion judge failed to consider the specific circumstances and unique characteristics of Defendant as a juvenile.In 1996, Defendant, who was seventeen, committed crimes that resulted in his guilty plea to murder in the second degree, armed assault with intent to murder, and illegal possession of a firearm. Defendant was sentenced to life imprisonment for murder and two sentences of five to seven years' imprisonment for the assaults to run concurrent to each other but consecutive to the life sentence. After Defendant was paroled from his life sentence he moved to vacate the remaining sentences and for resentencing under Rule 30(a). The motion judge denied the motion. The Supreme Judicial Court remanded the matter to consider whether Defendant's sentences comported with article 26 of the Massachusetts Declaration of Rights, holding (1) 120 Code Mass. Regs. 200.08 distinguishes parole for life sentences from other sentences and is therefore invalid; and (2) because Defendant already served the aggregate minimum of his sentences, he was immediately entitled to a parole hearing. View "Commonwealth v. Sharma" on Justia Law