Justia Juvenile Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions, entered upon his guilty plea, for involuntary manslaughter, having weapons while under a disability, and aggravated riot, holding that the juvenile court's probable cause determination was not subject to a manifest-weight challenge on appeal.The State filed a complaint in the juvenile court alleging that Defendant committed involuntary manslaughter and related offenses. The juvenile court determined that the State had established probable cause to believe that Defendant committed the offense and transferred Defendant's case to the general division. Defendant ultimately pled guilty. On appeal, Defendant argued that the juvenile court erred in transferring his case to the general division. The court of appeals affirmed. The Supreme Court affirmed, holding that a juvenile court's probable cause determination at a mandatory binder hearing is not subject to a manifest-weight review on appeal. View "State v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a person adjudicated a juvenile delinquent may not reopen his or her direct appeal from the adjudication based on a claim of ineffective assistance of appellate counsel under App.R. 26(B).The juvenile division of the court of common pleas adjudicated T.A. a delinquent child. The Ninth District Court of Appeals affirmed. T.A. subsequently filed an application to reopen his direct appeal under App.R. 26(B). The Ninth District denied the application, concluding that a child adjudicated delinquent may not apply for reopening of his or her appeal from the adjudication under the rule. The Supreme Court affirmed, holding that App.R. 26(B) does not apply to juvenile adjudications. View "In re T.A." on Justia Law

Kengi Moses appealed an amended order deferring imposition of sentence entered upon a conditional plea of guilty to unlawful possession of a firearm. The North Dakota Supreme Court affirmed, concluding that Moses’ prior juvenile adjudication qualified as a predicate conviction under the statute prohibiting possession of a firearm following a criminal conviction and that he received due process under the law. View "North Dakota v. Moses" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law

The Supreme Judicial Court vacated and set aside Appellant's conviction as a youthful offender and his adjudications of delinquency, holding that the trial judge erred in failing to conduct an inquiry into the jury foreperson's report of "discriminatory comments" being made during deliberations.Appellant, a juvenile, was found guilty for two firearm-related offenses. On appeal, Appellant argued that his right to a trial by a fair and impartial jury was twice violated at his trial. The court of appeals agreed, vacated the judgment and adjudications of delinquency, and set aside the verdicts. The Supreme Judicial Court affirmed, holding (1) the trial judge abused his discretion by not conducting a preliminary inquiry into the foreperson's report that the jury remained capable of impartially rendering a verdict; and (2) because it cannot be determined whether comments reflecting racial, ethnic, or other improper bias were made and, if so, whether they created a substantial risk of a miscarriage of justice, the case must be remanded for further proceedings. View "Commonwealth v. Ralph R." on Justia Law

In December 2018, the juvenile court committed Jhonny to the Division of Juvenile Justice (DJJ) for a maximum term of confinement of four years after he admitted on a petition under Welfare and Institutions Code section 602 committing felony assault with force likely to cause great bodily injury. In November 2020, Jhonny’s wardship and probation were successfully terminated; in October 2021, the DJJ granted him an honorable discharge. Jhonny sought to have his juvenile record sealed and his petition dismissed under sections 781 and 782, arguing that under section 1179(d), dismissal of his juvenile petition was mandatory based on his honorable discharge. The juvenile court granted Jhonny’s petition to have his juvenile record sealed but declined to dismiss his petition, citing section 782.The court of appeal reversed. The cited statutes deal with the same subject matter (dismissal of a juvenile petition) but there is a conflict arising from the use of mandatory language in section 1179(d) (the court “shall” dismiss) and discretionary language in sections 782 and 1772 (the court “may” dismiss). Under these circumstances, the specific statute must prevail. Only section 1179(d) addresses the specific issue raised here of the dismissal of the petition of an individual who has obtained an honorable discharge from the DJJ. View "In re Jhonny S." on Justia Law

The Supreme Court affirmed the judgment of the juvenile court placing MBP, a juvenile, on supervised probation for three to six months after adjudicating him delinquent for fighting in public, holding that the juvenile court did not err in either its adjudication or order of disposition.As part of the disposition, the juvenile court placed MBP on supervised probation for three to six months. MBP appealed, arguing that the evidence was insufficient establish to support the adjudication and that the sentence imposed was contrary to law. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the requisite intent and established an implicit agreement to fight; and (2) MBP failed to establish that the juvenile court's imposition of a three-to-six-month probationary term constituted plain error. View "MBP v. State" on Justia Law

In 2005, fifteen-year-old Davion Keel and eighteen-year-old Ariel Bolton held Barry Knight at gunpoint and robbed him of twenty dollars on the streets of San Bernardino. One of them shot and killed Knight when he resisted the robbery and tried to flee. Keel and Bolton were both prosecuted in adult criminal court and convicted of first degree murder in connection with Knight’s death. More than a decade later, Keel petitioned to vacate his murder conviction and to be resentenced under Penal Code section 1172.6 based on legislative changes to California's murder laws. The trial court denied the petition for resentencing, finding Keel was not entitled to relief because he remained liable for Knight’s murder because he was a major participant in the underlying robbery and he acted with reckless indifference to human life. Keel appealed, arguing the evidence was insufficient to support the trial court’s finding that he was a major participant in the underlying robbery who acted with reckless indifference to human life. In the alternative, he contended the court applied an incorrect legal standard when it adjudicated his petition for resentencing. The Court of Appeal agreed with Keel’s first argument, which rendered it unnecessary to reach his second argument. Because there was insufficient evidence to support the trial court’s determination, the Court reversed the order denying Keel’s resentencing petition and remanded the matter to the trial court with directions to grant Keel’s resentencing petition and vacate his murder conviction. Further, the Court concluded Proposition 57, the Public Safety and Rehabilitation Act of 2016, and Senate Bill 1391 (2017–2018 Reg. Sess.) would apply retroactively to Keel once his petition for resentencing was granted and his murder conviction was vacated. Therefore, on remand, the Court instructed the trial court to transfer the matter to the juvenile court for resentencing in accordance with those measures. View "California v. Keel" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court denying Gunner B.'s motion for a new trial after the juvenile court entered an order finding that Gunner was a child within the meaning of Neb. Rev. Stat. 43-247(1), holding that Gunner's assignments of error were without merit.The State filed a petition alleging that Gunner was a child within the meaning of section 43-247(1) and had committed sexual assault in the third degree, as that crime is set forth in Neb. Rev. Stat. 28-320(1) and (3). The juvenile court found that Gunner was a child within the meaning of section 43-247(1) and set the case for disposition. After the juvenile court denied Gunner's ensuing motion for a new trial Gunner appealed. The Supreme Court affirmed, holding that Defendant's assignments of error were without merit and that the evidence was sufficient to prove Gunner's guilt beyond a reasonable doubt. View "In re Gunner B." on Justia Law

Javier Garza was found guilty of third degree rape when he was 17 years old. Twenty-five years after his adjudication, Garza successfully petitioned for relief from registering as a sex offender. Garza then moved to vacate and seal his juvenile adjudication under RCW 13.50.260(3). The court found it had no authority to vacate juvenile adjudications under this provision and denied the motion. The Court of Appeals affirmed on different grounds, holding that because RCW 13.50.260(3) applied only to “order[s] and findings,” juvenile adjudications did not qualify because adjudications were judgments, not orders. The issue this case presented for the Washington Supreme Court's review was whether a juvenile adjudication could be vacated and sealed under RCW 13.50.260(3). Because the plain language of the statute grants trial courts discretion to vacate and seal both adjudications and diversions, the Supreme Court held that juvenile adjudications could be vacated and sealed under RCW 13.50.260(3). The Court reversed the Court of Appeals and remanded for a new hearing. View "Washington v. Garza" on Justia Law