Justia Juvenile Law Opinion Summaries

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

Two children, S and P, who are members of the Pit River Tribe, were the subject of juvenile dependency proceedings in Oregon. The Department of Human Services (DHS) initially pursued reunification with their mother as the permanency plan. However, after DHS determined that reunification was no longer safe or feasible, it petitioned to change the plan to tribal customary adoption (TCA), a process recognized under the Oregon Indian Child Welfare Act (ORICWA) that allows for adoption through tribal custom without terminating parental rights. The juvenile court held a contested permanency hearing, received evidence from DHS, the tribe, and a qualified tribal expert, and ultimately found by clear and convincing evidence that TCA was an appropriate permanent placement and in the children’s best interests. The court then requested the tribe to submit a formal order or judgment evidencing completion of the TCA.After the tribe submitted its TCA resolution, the juvenile court scheduled a hearing to consider whether to accept the tribe’s documentation. At this hearing, the mother objected, arguing that she was entitled to a contested evidentiary hearing to challenge the TCA and that the court was required to make an independent best-interests determination. The juvenile court accepted the tribe’s resolution, entered judgment for TCA, and terminated its jurisdiction over the children. The mother appealed, raising procedural and substantive challenges to the process.The Oregon Supreme Court reviewed whether the juvenile court was required to hold a contested evidentiary hearing before accepting the tribe’s TCA order or judgment. The court held that neither ORICWA nor the TCA statute requires a juvenile court to conduct a contested evidentiary hearing after a tribe submits its completed TCA documentation. The court found that the required determinations—including whether TCA is an appropriate permanent placement and is in the child’s best interests—are made at the permanency hearing, and the TCA hearing is not intended to relitigate those issues. The Supreme Court affirmed the decisions of the Court of Appeals and the circuit court. View "Dept. of Human Services v. M. G. J." on Justia Law

A juvenile, K.I.B., was adjudicated delinquent in June 2024 by the Juvenile Court of Burleigh County, South Central Judicial District, for promoting a sexual performance by a minor and possession of prohibited materials, both felonies under North Dakota law, as well as giving false information to law enforcement. In January 2025, the court held a hearing to determine whether K.I.B. was required to register as a sexual offender. The court found that K.I.B. had no prior sexual offender offenses and did not exhibit mental abnormality or predatory conduct during the commission of the offenses, and therefore exempted K.I.B. from the registration requirement.The State appealed the exemption order to the Supreme Court of North Dakota, arguing that the juvenile court erred in interpreting its discretion under N.D.C.C. § 12.1-32-15. The State asserted its standing to appeal based on statutory language and public safety interests. The Supreme Court reviewed the statutory interpretation de novo, focusing on whether the juvenile court had discretion to exempt K.I.B. from registration under the relevant statute.The Supreme Court of North Dakota held that N.D.C.C. § 12.1-32-15(2)(a) mandates registration for individuals adjudicated as felonious sexual offenders, including juveniles, unless the offense falls under a specific exception listed in subdivision (c), which did not apply to K.I.B. The court concluded that the juvenile court misapplied the law and abused its discretion by exempting K.I.B. from registration. The Supreme Court reversed the juvenile court’s order and remanded the case for entry of judgment consistent with its opinion, requiring K.I.B. to register as a sexual offender. View "Interest of K.I.B." on Justia Law

Several minors were injured at trampoline parks operated by Sky Zone in Philadelphia. In each instance, only one parent signed a “Participation Agreement, Release and Assumption of the Risk” on behalf of their child, which included an arbitration provision waiving the right to sue in court. After the injuries, both the signing and non-signing parents, along with the injured minors, brought lawsuits seeking damages for the injuries sustained at the facilities.The Court of Common Pleas of Philadelphia County reviewed petitions by Sky Zone to compel arbitration and stay the litigation, relying on the signed agreements. The trial courts denied these petitions, finding that the agreements were enforceable only against the signing parent. The courts determined that a spouse does not have authority to act as the agent of the other simply by virtue of marriage, and Sky Zone had not provided evidence of agency. Additionally, the courts held that parents do not have the legal authority to waive a minor’s right to pursue personal injury claims or to bind a minor to an arbitration agreement that would require waiving the right to a judicial forum.The Superior Court of Pennsylvania affirmed the trial courts’ decisions, holding that neither the non-signing parents nor the minors were bound by the arbitration provisions. The Superior Court reasoned that agency cannot be inferred from family ties alone and that parents, as natural guardians, lack inherent authority to manage a minor’s property, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s orders. The Court held that a parent who signs an arbitration agreement cannot bind a non-signing spouse or a minor child to its terms. Specifically, parents lack the authority to bind a minor to an agreement to arbitrate, as this would deprive the minor of judicial protections and oversight designed to safeguard their interests. View "Shultz v. Sky Zone, LLC" on Justia Law

A married couple with a young child became involved in a physical altercation at their home, during which the father, while intoxicated, struck the mother multiple times. During the incident, the mother was holding their infant son, and the father accidentally hit the child in the face, though the child was not injured. The mother sustained injuries, including a lacerated lip and a cut foot. The police responded, and the father was arrested for domestic violence and child endangerment. Both parents later gave conflicting accounts to social workers, with the mother initially reporting prior incidents of domestic violence, including while she was pregnant or breastfeeding, but later recanting some statements. The father admitted to slapping the mother but denied hitting the child or prior violence.The Los Angeles County Department of Children and Family Services filed a dependency petition under Welfare and Institutions Code section 300, subdivisions (a) and (b), alleging risk of harm to the child due to domestic violence and the father’s substance abuse. The Superior Court of Los Angeles County detained the child from the father, released him to the mother, and ordered services for both parents. At the combined jurisdictional and dispositional hearing, the court found the mother’s initial statements credible, sustained the domestic violence and substance abuse allegations, declared the child a dependent, and removed him from the father’s custody.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that substantial evidence supported the jurisdictional findings under both subdivisions (a) and (b) based on the parents’ history of domestic violence in the child’s presence, including the incident where the father accidentally struck the child. The court also found substantial evidence supported the removal order, given the ongoing risk and the parents’ lack of accountability. The appellate court affirmed the juvenile court’s findings and orders. View "In re Miguel J." on Justia Law

After the birth of A.M., the Los Angeles County Department of Children and Family Services became involved due to concerns about the mother’s substance abuse and the father’s alleged failure to protect A.M. from the mother. The juvenile court initially placed A.M. with her father, who lived with his sister Martha and other family members, and later awarded him sole physical custody. Years later, the father was incarcerated after police found a gun and pills in his car. Before going to prison, he arranged for Martha to care for A.M., providing her with necessary documents and a notarized letter for temporary custody. However, when the mother learned of the father’s incarceration, she refused to return A.M. to Martha after a visit. The mother’s care was found to be inadequate, with evidence of substance abuse, neglect, and unsafe living conditions, leading to A.M. being placed back with Martha.The Superior Court of Los Angeles County detained A.M. from both parents, citing concerns about the father’s criminal history and the mother’s conduct. The court found that the father’s incarceration and criminal actions impaired his ability to parent and protect A.M., and removed A.M. from both parents under various provisions of the Welfare and Institutions Code. Both A.M.’s counsel and the father’s counsel argued that the father had made an appropriate care plan, but the court disagreed and ordered removal.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that a juvenile court may not remove a child from an incarcerated parent solely due to incarceration if the parent has made a suitable plan for the child’s care. The court found no substantial evidence that the father’s plan posed a risk to A.M. and reversed the portion of the order removing A.M. from her father, remanding for further proceedings as appropriate. View "In re A.M." on Justia Law

The case concerns a family in Evanston, Wyoming, where the State intervened after a five-day-old infant, SP, was hospitalized with a cerebral hemorrhage. Law enforcement took SP and three other minor children into protective custody, suspecting abuse or neglect by their parents, particularly focusing on the father, who is hearing-impaired and sometimes requires an ASL interpreter. The State filed a petition alleging abuse, and both parents initially denied the allegations. The children were placed in the custody of the Department of Family Services, and a permanency plan for family reunification with the mother was adopted.The District Court of Uinta County held several hearings, ensuring the father had access to an interpreter and legal counsel. During the proceedings, concerns about the father’s competency arose, but no formal motion for a competency evaluation was made. The father ultimately stipulated to the adjudication of neglect after being advised of his rights and confirming his understanding and voluntariness. Later, the father’s counsel sought to withdraw, citing communication difficulties, but the court denied the motion, finding no extraordinary circumstances. When the father was incarcerated out of state, the court attempted to facilitate his participation in the disposition hearing, but he could only appear by phone, which was ineffective due to his hearing impairment. The court proceeded, denied the father’s motion to dismiss, and ordered the children to remain in state custody.The Supreme Court of Wyoming reviewed the case and affirmed the lower court’s decisions. The Court held that deficiencies in the neglect petition did not deprive the juvenile court of subject matter jurisdiction, that a parent in neglect proceedings does not have a due process right to a competency evaluation, and that the court did not abuse its discretion in denying counsel’s withdrawal. The Court also found no due process violation in proceeding with the disposition hearing without the father’s physical presence, given the circumstances and his representation by counsel. View "In the Interest of SP v. The State of Wyoming" on Justia Law

Gregory D. is the father of X.D., a child born in 2014. In 2015, Gregory D. kidnapped X.D. and her mother, assaulted the mother, and endangered X.D., leading to a prior dependency proceeding in which the mother was granted full custody and the father was allowed monitored visits, though he rarely exercised them. In December 2023, X.D.’s mother was killed during a violent incident, leaving X.D. without a parent to care for her. At that time, Gregory D. was incarcerated and had not been in contact with X.D. for years. X.D. was placed with her maternal grandmother.The Los Angeles County Department of Children and Family Services filed a petition in the Superior Court of Los Angeles County seeking dependency jurisdiction over X.D. under Welfare and Institutions Code section 300, subdivisions (b) and (g), citing the absence of a parent able to provide care. After Gregory D.’s whereabouts were discovered, he suggested his mother and brother as possible caregivers. The Department investigated and found the paternal grandmother’s home unsuitable due to her health and living conditions, and the paternal uncle was unresponsive and already caring for two young children. X.D. expressed fear of her father and no interest in living with his relatives.The California Court of Appeal, Second Appellate District, Division Five, reviewed the case. The court held that dependency jurisdiction under section 300, subdivision (g), is appropriate when an incarcerated parent cannot arrange for suitable, reliable, or appropriate care for the child, even if the parent suggests relatives who are unwilling or unable to provide such care. The court affirmed the juvenile court’s order exerting dependency jurisdiction over X.D. and ordering reunification services for Gregory D. View "In re X.D." on Justia Law

Police received reports of a group committing robberies or attempted robberies in a white Nissan Rogue that had been reported stolen. Officers tracked the vehicle, observed it being driven recklessly, and saw it crash. Four individuals, including E.A., fled from the car. E.A. was apprehended shortly after the crash, frisked, and found to have a handgun in his sweatshirt pocket. He was subsequently charged with carrying a pistol without a license and possession of an unregistered firearm.The Superior Court of the District of Columbia denied E.A.’s motion to suppress the handgun, finding that officers had reasonable articulable suspicion to stop and frisk him based on his association with the group suspected of recent robberies and the stolen vehicle, as well as his flight from the crash. The court also concluded that, even if the officers’ actions exceeded the scope of a Terry stop, they had probable cause to arrest E.A. for multiple offenses, justifying a search incident to arrest. E.A. was adjudicated delinquent on both firearms charges and appealed, challenging the denial of his suppression motion.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the officers had reasonable articulable suspicion to stop and frisk E.A., relying on the collective knowledge from radio dispatches, corroborated by officers’ observations and the circumstances of the stop. The court further held that the officers’ use of handcuffs and drawn weapons did not convert the stop into an arrest, given the safety concerns and flight risk. Therefore, the search and seizure of the handgun did not violate the Fourth Amendment, and the judgment was affirmed. View "In re E.A." on Justia Law

A child was removed from her parents’ care shortly after birth due to concerns about neglect. The mother, who has cognitive disabilities, was unable to provide basic care, resulting in the child’s hospitalization for weight loss. The father, who also has an intellectual disability, did not live with the mother and child and was unable to take custody when the child was discharged from the hospital. Both parents were found responsible for neglect, and the New Hampshire Division for Children, Youth and Families (DCYF) was awarded legal custody. The parents were ordered to meet certain conditions, including maintaining safe housing, engaging with mental health providers, and participating in parenting education, while DCYF was required to provide supportive services.The Circuit Court–Concord Family Division held periodic review hearings, finding the parents in only partial compliance with the orders. The mother struggled to care for the child outside of supervised settings and failed to secure appropriate housing. The father also lacked housing and did not fully engage with required services. After twelve months, the court determined that neither parent had corrected the conditions leading to the neglect finding and established adoption as the permanency plan. DCYF then petitioned to terminate both parents’ rights. The trial court granted the petitions, finding that DCYF made reasonable efforts to assist both parents and that termination was in the child’s best interest.The Supreme Court of New Hampshire reviewed the case. It held that non-compliance with the Americans with Disabilities Act (ADA) cannot be asserted as a defense in a termination of parental rights proceeding. The court also found that the evidence supported the trial court’s findings regarding the mother’s failure to correct the neglect conditions, DCYF’s reasonable efforts, and the determination that termination was in the child’s best interest. The orders terminating parental rights were affirmed. View "In re K.O." on Justia Law