Justia Juvenile Law Opinion Summaries

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In this appeal concerning a condition of probation requiring Ricardo P. to submit to warrantless searches of his electronics devices the Supreme Court held that the electronics search condition was not reasonably related to future criminality and was therefore invalid under People v. Lent, 15 Cal.3d 481 (1975). In Lent, the Supreme Court held that "a condition of probation which requires or forbids conduct which is not itself criminal is valid if that conduct is reasonably related to the crime of which the defendant was convicted or to future criminality." Ricardo, a juvenile, was placed on probation after admitting two counts of felony burglary. As a condition of his probation, the juvenile court imposed the electronics search. Although there was no indication Defendant used an electronic device in connection with the burglaries, the court imposed the condition in order to monitor Ricardo's compliance with separate conditions. The court of appeals concluded that the condition was unconstitutionally overbroad and should be narrowed but held that the condition was permissible under Lent because it served to prevent future criminality. The Supreme Court disagreed, holding that the electronics search condition was not reasonably related to future criminality. View "In re Ricardo P." on Justia Law

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The Supreme Judicial Court remanded this case for entry of a judgment vacating the juvenile court's order denying Juvenile's motion to dismiss a delinquency complaint issued against him, holding that the juvenile court judge erred in deciding that a probable cause finding in a prior case was sufficient to establish that the instant complaint was not the juvenile's "first offense" of a six months or less misdemeanor under Mass. Gen. Laws ch. 119, 52. A delinquency complaint issued against Juvenile that charged him with a misdemeanor that carried a maximum penalty of imprisonment of less than six months. Juvenile moved to dismiss the complaint, arguing that because he had not previously been adjudicated delinquent for any offense, the charge must be dismissed because it was a "first offense" under section 52. The juvenile court denied the motion, determining that because Juvenile had previously been charged with a separate offense for which probable cause had been found, under the amended statute the new charge was not the Juvenile's first offense. The Supreme Judicial Court remanded the matter, holding (1) the term "first offense" under section 52 means a first adjudication of delinquency; and (2) a first offense under the statute can include an offense that did not result in a prior delinquency. View "Wallace W. v. Commonwealth" on Justia Law

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In 2018, the court of appeal held that a juvenile court’s order committing a minor to the Department of Juvenile Facilities (DJF) must be supported by “some specific evidence in the record of the programs at the DJF expected to benefit a minor.” Citing that case, A.M. challenged the juvenile court’s order committing him to the DJF. A.M. had admitted to driving his brother to a park, knowing his brother intended to commit murder. The court of appeal upheld the commitment order, noting testimony by a DJF official about the programs offered by DJF and DJF publications further describing the programs. The juvenile court could reasonably find that certain DJF programs would benefit Minor: group sessions with other youths, a program to help identify negative peers, impulse control therapy, anger management, and/or individual therapy. Minor apparently argued that he has no need for any of these programs, based on the descriptions in the letters from his family and others. The juvenile court found otherwise, discounting those descriptions as irreconcilable with the nature and circumstances of the offense and with Minor’s performance on probation. Substantial evidence supports that finding. View "In re A.M." on Justia Law

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The State of New Hampshire filed a petition for original jurisdiction seeking review of a circuit court order denying a request by the Office of the Attorney General (AGO) to release records underlying its investigation into an incident involving minors. According to the AGO, in 2017, there was an incident involving several minors in Claremont, New Hampshire. The AGO, the United States Attorney’s Office, the Federal Bureau of Investigation, and the Claremont Police Department jointly investigated the incident. Subsequently, the Sullivan County Attorney filed delinquency petitions in the circuit court against one of the juveniles. The AGO asserted that the evidence obtained during the investigation was not confidential under RSA 169-B:35 but, even if it were, “significant policy considerations” allowed disclosure as long as the juvenile’s identity was protected. Following a hearing, the trial court rejected the AGO’s argument that RSA chapter 169-B did not apply to the AGO’s investigatory records. The court stated that “RSA 169-B:35 provides that all case records relative to delinquencies are confidential. Publication of information concerning a juvenile case is strictly prohibited with few legislatively enacted exceptions. None of those exceptions apply in this case.” The New Hampshire Supreme Court affirmed the circuit court’s ruling that the records were confidential under RSA 169-B:35 (Supp. 2018). View "Petition of the State of New Hampshire" on Justia Law

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For the reasons stated in People v. Superior Court (T.D.), the Court of Appeal rejected the district attorney's claim that Senate Bill No. 1391 unconstitutionally amended Proposition 57. The court also addressed issues not before the court in T.D., and held that Senate Bill No. 1391 is not an unconstitutional amendment of Proposition 21, the Gang Violence and Juvenile Crime Prevention Act of 1998 (Proposition 21); is not unconstitutionally vague; and applies retroactively. In this case, the court held that the murder charge against real party in interest I.R. allegedly committed when he was age 15 cannot be transferred to criminal court based on a separate felony offense he allegedly committed when he was age 17. Therefore, the court denied the petition for writ of prohibition and/or mandate. View "People v. Superior Court (I.R.)" on Justia Law

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Senate Bill No. 1391 does not unconstitutionally amend Proposition 57. Proposition 57, the Public Safety and Rehabilitation Act of 2016, eliminated a prosecutor's ability to directly file charges in criminal (adult) court against minors who were 14 years of age or older at the time of their alleged offenses, and instead required prosecutors to obtain juvenile court approval to do so. SB 1391 prohibits the transfer of 14- and 15-year-old offenders to criminal court in virtually all circumstances. The Court of Appeal held that voters intended Proposition 57 to extend as broadly as possible; the amendatory language of section 5 of the Act was ambiguous; and, when the court construed the language and the Act as a whole consistently with the voters' intent, SB 1391 was constitutional. Accordingly, the court discharged the order to show cause previously issued and denied the petition for writ of mandate. View "People v. Superior Court (T.D.)" on Justia Law

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A.L. was in a fight with her sister violent enough for police to be called. An officer grabbed A.L.’s arm, stating “I saw you kick her when she was down.” She pulled away. Another officer took her other arm. She dropped to the pavement, kicking and scratching the officer before biting him. He punched A.L. and put her in handcuffs. The District Attorney filed a juvenile wardship petition under Penal Code sections 243(b) (battery on a peace officer); 69 (resisting a peace officer by force); and 148(a)(1) (resisting a peace officer). Resisting an officer and forcefully resisting an officer require actual knowledge that an officer is engaged in the performance of duty. The juvenile court stated: “Whether you think the police have the right to detain you or stop you or hold onto you, the law in this state says you don’t get to resist” and sustained the allegations. The court of appeal affirmed, finding the judge's comment not so ambiguous as to require reversal. The court may have found that the statutes were violated so long as the officers were performing their duty, without regard to A.L.’s awareness of that fact, or may have been referring only to section 243(b) and correctly describing the law. The court expressly found that the necessary elements for all three offenses had been proven beyond a reasonable doubt; those elements include the actual knowledge requirement of sections 69 and 148(a)(1). View "In re A.L." on Justia Law

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E.C. alleged she was sexually assaulted on the premises of Pass Christian High School. The Youth Court adjudicated the alleged perpetrators not delinquent. Later, Roy and Kimberly Cuevas, individually, and on behalf of their minor daughter, E.C., filed a negligence action seeking damages from the Pass Christian School District associated with the alleged assault. Pass Christian unsuccessfully sought the records from the youth-court action to use in its defense in the civil case. It argued on appeal that the youth-court judge abused her discretion in denying its requests for disclosure of the youth-court records and trial transcripts relating to the three minor perpetrators. It also argued it would be denied due process and fairness if the sworn testimony of E.C. were not released due to the confidentiality rules protecting the subjects of youth-court actions. The Mississippi Supreme Court reversed and remanded for the circuit court to conduct an in camera review of the youth-court record to determine whether any of it should have been disclosed. View "In the Interest of M.D.G. v. Harrison County Youth Court of Mississippi" on Justia Law

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At issue in this case was a Family Court order adjudging appellant Joseph Baker, Jr., a minor child, delinquent for having committed an act of Rape in the Second Degree. Initially, Baker was charged with three counts of Rape in the Second Degree. Count Two was voluntarily dismissed by the State before trial. At trial, the Family Court judge found Baker delinquent on Count One and acquitted him on Count Three. On appeal, Baker argued the judgment of delinquency for the one count of Rape in the Second Degree should be reversed because of evidentiary errors made by the Family Court judge at trial. The Delaware Supreme Court agreed that errors were made and reversal was required. View "Baker v. Delaware" on Justia Law

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The Court of Appeal held that Local Rule Seven of the McCourtney Courthouse Policies, effective August 13, 2019, is invalid; the rule was adopted in violation of state law; the local rule conflicts with California law; the goal of expediting proceedings cannot justify denying mother the opportunity to present relevant evidence; and the court may control courtroom proceedings through case-specific orders. In this case, the juvenile court refused to permit mother to testify or to call witnesses in a juvenile dependency matter set for a contested dispositional hearing, because her counsel had not filed a joint trial statement as required by the local rule. The court also held that, even had the local rules here been properly adopted and enforceable, the juvenile court's ruling barring mother from testifying and examining her daughter on the statements contained in a report to the court because she had failed to submit the joint trial statement would run afoul of Code of Civil Procedure section 575.2. Furthermore, the sanction imposed was disproportionate to the conduct it punished. Accordingly, the court reversed the dispositional orders and remanded to the juvenile court with instructions to conduct a new dispositional hearing without reference to the local rule. View "In re Harley C." on Justia Law