Justia Juvenile Law Opinion Summaries

The Louisiana Supreme Court granted the State’s application to review the court of appeal’s determination that the State failed to prove that 16-year-old D.W. was the person who entered a sheriff’s vehicle and stole firearms from inside it, and therefore that the evidence was insufficient to support the delinquency adjudication for burglary involving a firearm, La. R.S. 14:62, and theft of a firearm, La. R.S. 14:67.15. After reviewing the record, the Supreme Court found the State presented sufficient evidence that D.W. was a principal, in accordance with La. R.S. 14:24, to these felony-grade delinquent acts regardless of whether he personally entered the vehicle and took the firearms that were inside it himself. Therefore, the Court reversed the ruling of the court of appeal and reinstated the delinquency adjudication and dispositions imposed by the juvenile court, which were then affirmed. View "Louisiana in the interest of D.W." on Justia Law

The Supreme Court affirmed the order of the juvenile court granting the State's delinquency petition against Defendant and its motion to waive jurisdiction to allow for Defendant's prosecution as an adult, holding that the juvenile court did not abuse its discretion in granting the waiver and that there was sufficient evidence to support Defendant's conviction.One month after his seventeenth birthday Defendant committed second-degree sexual abuse. The juvenile court issued an order waiving jurisdiction, concluding that there were not reasonable prospectives for rehabilitating Defendant if the juvenile court retained jurisdiction and that the waiver was in the bests interests of Defendant and the community. Defendant was found guilty after a jury trial. The Supreme Court affirmed, holding (1) a rational fact finder could determine beyond a reasonable doubt that Defendant committed second-degree sexual abuse based on the evidence presented; and (2) the juvenile court's waiver decision was supported by the evidence and reasonable. View "State v. Erdman" on Justia Law

While on juvenile parole related to a commitment to Oregon Youth Authority (OYA) in an earlier case, B.Y. was adjudicated to be within the jurisdiction of the juvenile court for interfering with a peace officer. Based on that conduct, the juvenile court imposed a new disposition, which also committed B.Y. to OYA custody, to commence at the conclusion of his existing commitment. B.Y. challenged that order, contending that the juvenile court lacked authority to impose consecutive commitments. A divided panel of the Court of Appeals agreed with B.Y. and reversed the juvenile court. The Oregon Supreme Court reversed the appellate court: “the statutory text neither expressly permits nor expressly prohibits the imposition of consecutive commitments. The statutory scheme does, however, confer broad authority on the juvenile court to fashion appropriate dispositions; that stands in contrast to the criminal code, where courts’ sentencing authority is more circumscribed. Given that contrast, the fact that the legislature did not explicitly provide for consecutive commitments in a circumstance such as this is unsurprising. In light of the wide latitude that the legislature has chosen to give juvenile courts, it is more reasonable to expect that if the legislature had intended to limit the juvenile court’s ability to impose consecutive commitments in this circumstance, the legislature would have indicated as much.” View "Oregon v. B. Y." on Justia Law

The juvenile court sustained the petition filed by the Los Angeles County Department of Children and Family Services alleging that Maira H. and Appellant, had a history of engaging in violent physical and verbal altercations in the presence of the children. At disposition the court declared the children dependents of the court, removed them from Appellant’s care and released them to Maira. Appellant appealed the December 2, 2021, findings and orders. Prior to Appellant’s filing of his opening brief on appeal, the juvenile court terminated its jurisdiction and issued custody orders, based on the parents’ mediated agreement, providing for joint legal and physical custody of the children with their primary residence to be with Maira. The custody orders include a parenting plan that specifies a visitation schedule for Appellant and allows for additional visitation as agreed by both parents. Appellant did not appeal the order terminating jurisdiction or the custody orders. The Department contends termination of dependency jurisdiction moots Appellant’s appeal.   The Second Appellate District agreed with the Department and dismissed Appellant’s appeal as moot. The court explained that although Appellant is no doubt correct that the jurisdiction findings impacted the custody orders entered by the juvenile court, to provide Appellant with effective relief, the court would have to reverse not only the jurisdiction findings and disposition orders but also the orders terminating jurisdiction and determining visitation. Accordingly, the court explained that because he did not appeal the September 22, 2022, custody and visitation orders, those orders are not now before the court or otherwise subject to appellate review. View "In re Jose C." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying T.D.'s motion for relief from judgment under Trial Rules 60(B)(6) and 60(B)(8) asserting that his juvenile adjudication should be set aside because his delinquency admission was not knowing, intelligent, or voluntary, holding that there was no error.T.D. agreed to admit to an auto-theft charge. Without informing T.D. of his constitutional rights or confirming that he waived those rights the court accepted T.D.'s admission and granted the delinquency petition. T.D. later filed a motion for relief from judgment, arguing that he was not "informed of a single right on the record." The trial court denied the motion, concluding that his admission was voluntary and knowingly given with adequate assistance of counsel. The Supreme Court reversed, holding that T.D. made a prima facie showing that the trial court failed to comply with the Juvenile Waiver Statute before accepting his admission, and therefore, the trial court abused its discretion by denying T.D.'s motion for relief from judgment. View "T.D. v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying the motion filed by H.M., a youth held in detention, seeking to dismiss a formal petition brought by the State to adjudicate H.M. as a delinquent youth, alleging one count of misdemeanor resisting arrest and three counts of assault on a police officer, holding that the district court did not err in denying the motion.As grounds to dismiss the petition H.M. argued that the State filed it one day beyond the seven-day time limit for such petitions against detained youths in Mont. Code Ann. 41-5-1401(2). The youth court declined to dismiss the petition, concluding that the State had good cause to file the petition and to detain H.M., outside the seven-day deadline. The Supreme Court affirmed, holding (1) the good cause exception in section 41-5-1401(2) applies to the youth court's decision not to dismiss an untimely petition charging a youth held in detention; and (2) the youth court properly denied H.M.'s motion to dismiss. View "In re H.M." on Justia Law

At age 16, defendant Tory Bratton confessed to robbing a local market, with an accomplice, shooting the clerk dead, and taking $184. At his trial, his counsel argued that defendant’s confession was false and that he did not participate in the robbery at all. However, trial counsel did not argue that, even if defendant did participate, he was not the shooter. Defendant was convicted of (among other things) first degree murder, with a personal firearm use enhancement and felony-murder special circumstances. He appealed; the Court of Appeal affirmed. When defendant filed a petition to vacate the murder conviction under Penal Code section 1172.6, the trial court denied it; it ruled that the Court of Appeal's opinion in defendant’s direct appeal showed that he was the actual killer. The State conceded that this was error, but that the error was harmless because the record of conviction established defendant was the actual killer. Anticipating this response, defendant argued that, under standard principles of issue preclusion (a/k/a collateral estoppel), preclusion did not apply here because: (1) Whether defendant was the shooter was not actually litigated; (2) Trial counsel had an incentive not to contest whether defendant was the shooter; (3) The significance of whether defendant was the shooter was small at trial but, due to the then-unforeseeable enactment of section 1172.6, has since become great; (4) Section 1172.6 was a significant change in the law that warranted reexamination of whether defendant was the shooter. The Court of Appeal agreed that standard principles of issue preclusion applied here. However, the Court held that the issue of whether defendant was the shooter was actually litigated. Moreover, trial counsel did have an incentive to contest this issue; evidently, he simply made a tactical decision not to. Because trial counsel did have an incentive to contest the issue, it did not matter that it was unforeseeable that the issue would have additional future consequences. And finally, while section 1172.6 was a significant change in the law, the Legislature intended that it not constitute an exception ipso facto to issue preclusion. View "California v. Bratton" on Justia Law

Michael Reynolds Jr. received a mandatory sentence of life in prison without possibility of parole for a crime he committed at age 33. The events triggering that sentence, though, were his two “strikes” under Washington’s “three strikes” law—one of which Reynolds committed at age 17, when he was a juvenile. If Reynolds’ current sentence constituted punishment for his earlier offense committed at age 17, then it would be unconstitutional under case law. But under the Washington Supreme Court’s more recent precedent, his current sentence did not constitute punishment for that prior offense. In Washington v. Moretti, decided two years after Bassett, the Supreme Court held that a “three strikes” sentence of mandatory life in prison without possibility of parole constituted punishment for the last crime or third “strike,” not the earlier first or second “strikes.” “And for years, we have held that our state’s ‘three strikes’ law as applied to adults does not violate article I, section 14.2 That assessment could certainly change over time. But in this case, the parties have not asked us to overrule it.” The Court therefore affirmed the Court of Appeals. View "Washington v. Reynolds" on Justia Law

Plaintiffs-appellants, nineteen children in New York City’s foster care system, filed suit alleging “systemic deficiencies” in the administration of the City’s foster care system in violation of federal and state law. The named Plaintiffs moved to represent a class of all children who are now or will be in the foster care custody of the Commissioner of New York City’s Administration for Children’s Services and two subclasses. As remedies, they sought injunctive and declaratory relief to redress alleged class-wide injuries caused by deficiencies in the City’s administration—and the New York State Office of Children and Family Services’ oversight—of foster care. The district court denied Plaintiffs’ motion for class certification. Plaintiffs appealed, arguing that the district court erred in its analysis of the commonality and typicality requirements under Federal Rule of Civil Procedure 23(a).   The Second Circuit vacated the district court’s order denying class certification and remanded. The court held that the district court erred in its analysis of commonality and typicality under Rule 23. The court explained that the district court did not determine whether commonality and typicality exist with respect to each of Plaintiffs’ claims. Instead, it concluded that commonality was lacking as to all alleged harms because “Plaintiffs’ allegations do not flow from unitary, non-discretionary policies.” The court held that this approach was legal error requiring remand. Further, the court wrote that here, the district court largely relied upon its commonality analysis to support its finding that typicality was not satisfied. Thus, the deficiencies identified in its commonality inquiry can also be found in its handling of typicality. View "Elisa W. v. City of New York" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court ordering A.R., who was adjudicated delinquent in a proceeding under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-5042, detained in a juvenile institution until he reached the age of twenty-one, followed by a term of juvenile delinquent supervision, holding that remand was required.A.R., who was born in 2003, was adjudicated delinquent pursuant to his admission of aiding and abetting an attempted robbery of a motor vehicle and five carjackings, each of which would have been a violation of 18 U.S.C. 2119 had A.R. been an adult. On appeal, A.R. primarily challenged the district court's order of a detention period rather than a probationary one. The First Circuit affirmed as to the court's imposition of detention but reversed and remanded as to two other matters, holding (1) A.R.'s disposition was both procedurally and substantively reasonable; (2) the district court erred in failing to recommend that A.R. be placed in a local detention facility; and (3) the district court erred in imposing a term of detention and supervision that together exceeded the applicable statutory maximum. View "United States v. A.R." on Justia Law