Justia Juvenile Law Opinion Summaries

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In this juvenile wardship proceeding in California, defendant M.B. admitted to attempting murder and related enhancement allegations. M.B. was committed to a secure youth treatment facility (SYTF) for a four-year baseline term of confinement and a maximum term of confinement of 22 years to life. On appeal, M.B. challenged the court's jurisdiction to modify an earlier order setting the maximum term of confinement at four years. He also argued that the indeterminate 22 years to life term was unauthorized and that his precommitment credits should be applied against his four-year baseline term rather than against the maximum term of confinement.The Court of Appeal held that the juvenile court had jurisdiction to enter the challenged order and rejected M.B.'s argument that equal protection principles required application of precommitment credits against the baseline term. However, the court agreed with M.B. and the Attorney General that the 22 years to life maximum term of confinement was unauthorized. As such, the court modified the juvenile court's order to specify the maximum term of confinement as 22 years and otherwise affirmed the order. View "In re M.B." on Justia Law

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The appellant C.B., the biological father of minor A.K., appealed from the January 2023 order of the juvenile court terminating his parental rights. The appellant argued that the juvenile court and the Calaveras County Health and Human Services Agency (the Agency) denied his due process rights to notice and an opportunity to participate in dependency proceedings to establish presumed father status. T.K., the minor’s mother (mother), joined in C.B.’s arguments. The Court of Appeal of the State of California Third Appellate District agreed, finding that the juvenile court and the Agency did not comply with duties to try to identify all of the minor’s alleged fathers, to give adequate notice to C.B. that his parental rights were at stake in the proceedings, or to give C.B. notice of specific important hearings. Thus, it reversed the order terminating parental rights. The facts of the case reveal that when the minor was born, the Agency received a report that the mother tested positive for methamphetamine, benzodiazepines, and sexually transmitted diseases. The mother did not inform C.B. about her pregnancy and initially identified D.C. as the alleged father of the minor. However, paternity testing later showed that D.C. was not the biological father, and C.B. was identified as the potential father. Despite this, C.B. was not given proper notice of the proceedings or properly informed about their importance, and his due process rights were violated. View "In re A.K." on Justia Law

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The case arises from an appeal by a minor, K.B., from the juvenile court's order denying his request to dismiss a juvenile justice petition and seal records pertaining to his commission of several criminal offenses, for which he was adjudged a ward of the court and placed on probation. K.B. argued that he had met the requirements for "satisfactory completion" of probation and therefore, the petition should be dismissed and records sealed despite his subsequent admission for possessing marijuana for sale, an infraction.The central legal issue in this case was the interpretation of Welfare and Institutions Code section 786, subdivision (c)(1), which provides that a subsequent wardship adjudication during probation does not preclude satisfactory completion unless it stems from "a felony offense or a misdemeanor involving moral turpitude." The Court of Appeal of the State of California Third Appellate District disagreed with the juvenile court's interpretation of the statute that any juvenile adjudication, even an infraction, precludes satisfactory completion of probation.The appellate court held that the language of the statute, when considered in light of its purpose and to avoid absurd results, meant that the limiting phrase "for a felony offense or a misdemeanor involving moral turpitude" applies equally to juvenile wardship adjudications and adult convictions. Hence, K.B.'s infraction did not preclude satisfactory completion of probation. The court reversed the juvenile court's order and remanded with instructions to dismiss the petition and seal all records pertaining to the dismissed petition. View "In re K.B." on Justia Law

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The Supreme Court of Pennsylvania considered whether a violation of a juvenile defendant's Fifth Amendment right is subject to appellate review for harmless error. The case involved Nazeer Taylor, who was charged with several serious felony offenses as a juvenile. The juvenile court transferred Taylor's case to adult criminal court, considering Taylor's refusal to admit guilt for his alleged offenses as a factor in its decision. The Supreme Court of Pennsylvania previously held that such consideration violated Taylor's Fifth Amendment right. In this appeal, the Supreme Court concluded that the violation constituted a structural error, not subject to a harmless error review. Given Taylor's current age of 27, neither the juvenile nor the adult criminal court had the statutory authority to conduct a new certification hearing. Consequently, the Supreme Court affirmed the order of the Superior Court reversing Taylor's conviction and discharging him. View "Commonwealth v. Taylor" on Justia Law

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This case involves a person identified as Tony R., who was committed to the Reaching Into Successful Endeavors (RISE) program for a term of 11 years or until he reached the age of 25, with a baseline term of four years. This was following his involvement in serious offenses, including attempted murder and second-degree robbery. Tony appealed from the juvenile court's denial of his request to reduce his baseline term of confinement at his first six-month review hearing. He argued that the court lacked the authority to deny his request or, in the alternate, that it had abused its discretion.At the six-month review, the court evaluated Tony's progress in relation to his rehabilitation plan, which included a series of programs and treatments aimed at addressing his needs. Tony had been participating in these programs successfully and was performing well academically. Despite this, the court denied his request for a reduction in his baseline term.The Court of Appeal of the State of California, First Appellate District, affirmed the juvenile court's decision. The appellate court found that the juvenile court did not abuse its discretion in denying Tony's request for a reduction in his baseline term. The appellate court noted that the law gives juvenile courts discretion to reduce the baseline term but does not require it to do so, and that the juvenile court's decision was within the bounds of reason under the applicable law and the relevant facts. View "In re Tony R." on Justia Law

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In the case at hand, the defendant, Timmy J. Rouleau, was convicted of multiple counts of sexual assault following a jury trial in the Superior Court of New Hampshire. The case involved claims that the defendant sexually assaulted the victim multiple times when she was between the ages of ten and thirteen. The Supreme Court of New Hampshire reviewed the case focusing on the trial court's decision to admit evidence about an Amazon "wish list" containing sexually oriented items. The defendant argued that the evidence was not intrinsic to the charged crimes and should not have been admitted.The Supreme Court of New Hampshire concluded that the wish list evidence was not intrinsic to the charged crimes, and thus, its admission was an error. However, the court ruled that this error was harmless beyond a reasonable doubt. The court reached this conclusion by considering the overwhelming evidence of the defendant's guilt presented at trial, including the victim's detailed testimony of the repeated sexual assaults. The court also noted that the wish list evidence comprised a small portion of the victim's testimony and was not mentioned in the State's closing argument. Therefore, even though the evidence was admitted erroneously, it did not affect the verdicts, and the court ultimately affirmed the convictions. View "State v. Rouleau" on Justia Law

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Glen Robert Anderson pleaded guilty to two counts of production and attempted production of child pornography, one count of enticement of a minor, and one count of interstate communication with intent to extort. The district court sentenced him to 20 years in prison and 12 years of supervised release, which is above the statutory minimum sentence of 15 years. Anderson appealed, contending that his sentence is substantively unreasonable. The United States Court of Appeals for the Eighth Circuit, however, affirmed the district court's decision. It held that the district court did not abuse its discretion in the sentencing. The court had carefully assessed the factors under 18 U.S.C. § 3553(a) and had explained its reasoning for choosing a sentence above the statutory minimum. The court had considered the nature and seriousness of Anderson's crimes as aggravating factors, while also taking into account mitigating factors such as Anderson's history of abuse and mental health issues. The court had not relied solely on the advisory Guidelines, which recommended a life sentence, but had used them as a starting point and then varied downward based on the specific circumstances of the case. Thus, Anderson's sentence was not deemed substantively unreasonable. View "United States v. Anderson" on Justia Law

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In this case, the Supreme Court of North Dakota reversed and remanded a juvenile court order that terminated the parental rights of T.W. to her children, J.C. and M.W. The children had been placed in foster care by the Ward County Human Services Zone due to child abuse by T.W. and A.W., and T.W. was sentenced to four years in custody after pleading guilty to three counts of child abuse. The State later filed a petition for termination of T.W.'s parental rights.The Supreme Court found that the juvenile court had abused its discretion when it took judicial notice of and considered evidence beyond the evidentiary record. The court also found that the juvenile court had made clearly erroneous findings, including incorrectly stating that the children had been in foster care for 1123 nights when they had actually been there for 877 nights. Although there was sufficient evidence to support the termination of T.W.'s parental rights, the court was unable to discern whether the juvenile court had relied on inadmissible evidence in its decision.As a result, the Supreme Court remanded the case with instructions for the juvenile court to issue an order based only on the evidence received at trial. The Supreme Court retained jurisdiction and requested that the juvenile court issue its new order within 20 days. View "Interest of J.C." on Justia Law

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In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

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In the Supreme Court of the State of Montana, defendant Nels Jerry Peterson appealed his conviction on the offense of sexual assault against his eleven-year-old step-granddaughter (Q.H.). The main contention was the District Court’s decision to permit evidence of Peterson’s prior sexual conduct with other young girls under M. R. Evid. 404(b) and 403. The court concluded that some of the evidence may have been admissible for a permissible purpose under Rule 404(b), but the potential for unfair prejudice substantially outweighed its probative value as presented. The details of Peterson’s prior sexual misconduct were not more abhorrent than the current charge. However, the frequency and manner of the State’s references to them throughout the trial risked inducing the jury’s hostility toward Peterson, resulting in unfair prejudice. Further, the State did not meet its burden to show no reasonable possibility that its use of the tainted evidence might have contributed to Peterson’s conviction. Therefore, the court reversed the conviction and remanded the case for a new trial. View "State v. Peterson" on Justia Law