Justia Juvenile Law Opinion Summaries

Defendant-appellant D.C. (minor) appealed a court order sustaining the State's petition made pursuant to Welfare and Institutions Code section 602. The petition alleged minor carried a concealed dirk or dagger on his person in violation of Penal Code section 21310. Minor argued, and the State conceded, reversal was called for because the juvenile court erred when it found the human trafficking affirmative defense set forth in Penal Code section 236.23 did not apply in his case. After review, the Court of Appeal agreed the juvenile court erred, but declined the parties’ invitation to find the requirements of the defense were met. The Court reversed and ordered a new hearing on the applicability of Penal Code section 236.23. View "In re D.C." on Justia Law

In 1978, 17-year-old Carl Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon. Over the span of three days, Brooks carjacked, robbed, and raped a woman while her son was present; attempted to rob a couple where gunfire between Brooks and the male victim led to the shooting death of the victim’s wife; carjacked and robbed a third woman; and threatened a fourth woman in her home, demanded financial information, and assaulted her. Brooks had prior convictions in both juvenile and adult court. At the time, sentencing in Washington was “indeterminate:” trial courts sentenced offenders to the maximum amount of time that could be served. But the amount of time the offender would actually serve was largely controlled by the Board of Prison Terms and Paroles (parole board) who would set the minimum term, taking into account recommendations by the trial court and prosecutor. The judge ordered five of the life sentences to run concurrently, and the remaining three to run consecutively, effectively sentencing Brooks to four consecutive “blocks” (or groupings) of life sentences. Both the prosecutor and the court recommended that the parole board give Brooks minimum terms of life. Departing from the recommendations slightly, the parole board set minimum terms of 20, 25, 25, and 20 years for the four blocks, for a minimum total of 90 years. Not long after Brooks was sentenced, the Washington legislature replaced the indeterminate sentencing system with a determinate system. For those sentenced under the former indeterminate sentencing system who were still incarcerated, the Indeterminate Sentence Review Board (ISRB) (the successor to the parole board) was directed to “attempt to make [parole] decisions reasonably consistent” with the Sentencing Reform Act. While Brooks has been serving his time, the United States Supreme Court held that mandatory life-without-parole sentences for juveniles violate the Eighth Amendment’s prohibition on cruel and unusual punishment. The Washington Supreme Court determined that by its plain language, RCW 9.94A.730 applies to Brooks’ sentence. The ISRB was ordered to provide Brooks with a hearing under RCW 9.94A.730 that presumed release. Accordingly, the Court granted the Personal Restraint Petitioned, reversed the Court of Appeals, and remanded to the ISRB for further proceedings. View "In re Pers. Restraint of Brooks" on Justia Law

At 21 years old, appellant Joshua Acosta, who was diagnosed with a form of high-functioning autism spectrum disorder, plotted with his codefendant, to kill their friend Katlynn’s parents, whom Acosta believed was physically and sexually abusing her. Acosta shot and killed Katlynn’s parents and a family friend who was at their house. A jury convicted Acosta of three counts of first degree murder and found true the multiple murder special circumstance and firearm enhancements. The trial court sentenced him to three consecutive terms of life without the possibility of parole (LWOP), plus an additional 75 years to life in prison. On appeal, Acosta claimed his LWOP sentences were unconstitutional and had to be modified to allow for future parole consideration. Much of his challenge related to California Penal Code section 3051, which granted the right to a youth offender parole hearing to juvenile offenders sentenced to LWOP, and to juvenile and young adult offenders sentenced to indeterminate or life terms, no matter how lengthy. According to Acosta, section 3051 violated equal protection because it denied young adult offenders sentenced to LWOP the right to a youth offender parole hearing. Acosta further contended his LWOP sentences violated the Eighth Amendment. The Court of Appeal rejected these contentions and affirmed the judgment. View "California v. Acosta" on Justia Law

The Supreme Court vacated K.C.G.'s delinquency adjudication and the modification of his probation based on that adjudication, holding that the juvenile court lacked subject matter jurisdiction.The delinquency at issue alleged that sixteen-year-old K.C.G. committed the offense of dangerous possession of a firearm in violation of Ind. Code 35-47-10-5. The juvenile court adjudicated K.C.G. a delinquent and modified his probation. On appeal, Defendant argued that the plain terms of the dangerous-possession statute showed it could not be a delinquent act. The Supreme Court vacated the delinquency adjudication, holding that because the statute defines the offense solely in terms of a "child" with an unauthorized firearm, the dangerous-possession statute does not apply to adults, and therefore, the State's petition did not allege a jurisdictional prerequisite - that K.C.G.'s conduct was "an act that would be an offense if committed by an adult." View "K.C.G. v. State" on Justia Law

The Second Circuit affirmed the district court's order granting a preliminary injunction in favor of Hartford and enjoining defendants, who are administrators and clerks at the Connecticut Superior Court, from enforcing a Connecticut statute that mandates automatic sealing of all judicial records and closure to the public of all court proceedings in criminal prosecutions of juvenile defendants transferred to the regular criminal docket.The court held that Public Act Number 19-187 is unconstitutional. The court concluded that the Courant has a qualified First Amendment right of access to criminal prosecutions of juveniles in regular criminal court. The court agreed with the district court that, for cases in criminal court, even those involving juvenile defendants, the "place and process" have historically been open to the public. Furthermore, public access plays a significant positive role in the functioning of the particular process in question. The court also concluded that the Act infringes on that right because it is not narrowly tailored to serve a compelling state interest. Finally, the court concluded that the Courant has shown that all four requirements for a preliminary injunction have been met. View "Hartford Courant Co., LLC v. Carroll" on Justia Law

The Court of Appeal reversed the trial court's denial of defendant's request to have his case transferred to juvenile court pursuant to the Public Safety and Rehabilitation Act of 2016 (Proposition 57) and Senate Bill No. 1391. Proposition 57 eliminated the ability of prosecutors to file charges against juveniles directly in a court of criminal jurisdiction.The court explained that SB 1391 effectively broadens the ameliorative benefit of Proposition 57 to 14 and 15 year olds by prohibiting prosecuting attorneys from moving to transfer individuals who commit certain offenses when they were 14 or 15 years old to adult court, unless they were "not apprehended prior to the end of juvenile court jurisdiction." Therefore, SB 1391 applies retroactively to defendants whose judgments are not yet final. The court explained that the fact that defendant is now over 25 years old does not change the court's conclusion that he is entitled to the retroactive benefit of Welfare and Institutions section 707, subdivision (a)(2), if his conviction was not final when SB 1391 was enacted. In this case, defendant was apprehended when he was still 15 years old and therefore section 707, subdivision (a)(2)'s exclusion, by its plain terms, does not apply to him. Furthermore, because a resentencing under section 1170, subdivision (d)(1) replaces the original sentence, the original sentence is no longer operative, and the finality of the original sentence is no longer material. The court remanded to the trial court with directions for the matter to be transferred to the juvenile court for a juvenile adjudication. View "People v. Hwang" on Justia Law

Defendant, when he was 18 years old, stabbed and killed a 15-year-old boy while trying to take his backpack and bag containing football gear. Defendant was convicted of robbery and felony murder with a special circumstance finding under Penal Code section 190.2, subdivision (a)(17), which mandates a sentence of death or life in prison without the possibility of parole. The trial court sentenced defendant to life in prison without the possibility of parole, plus one year for using a deadly or dangerous weapon.The Court of Appeal affirmed defendant's sentence, concluding that the felony murder special circumstance statute is not unconstitutionally vague as applied to defendant. In this case, defendant had notice of the conduct proscribed by section 190.2 and does not claim discriminatory prosecution. The court also concluded that defendant's sentence is not cruel and unusual under the Eighth Amendment; defendant forfeited his right to challenge the restitution fine and assessments; and the trial court's sentencing minute order and the abstract of judgment must be corrected. View "People v. Montelongo" on Justia Law

The Supreme Judicial Court answered three questions reported by the juvenile court judge regarding waiver, evidentiary rules, and discovery procedures for hearings conducted under the procedures set forth in Wallace W. v. Commonwealth, 482 Mass. 789 (2019).Juvenile allegedly committed a major misdemeanor against another minor, followed by a minor misdemeanor against the same victim in a separate incident. The Commonwealth moved for a Wallace W. hearing to prove the greater offense, after which the juvenile court judge reported questions of law to the Supreme Court. The Supreme Court concluded (1) the Commonwealth may proceed directly to trial on the greater offense that preceded the first offense, but the Commonwealth may not arraign on the minor misdemeanor until it proves the greater offense; (2) a juvenile's failure to move for a prearraignment Wallace W. hearing on the first offense does not provide subject matter jurisdiction over the first offense; (3) the evidentiary rules laid out in Commonwealth v. During, 407 Mass. 108 (1990), apply to Wallace W. hearings; and (4) notice of the alleged violation and some exchange of discovery are required prior to Wallace W. proceedings. View "Commonwealth v. Nick N." on Justia Law

A defendant who was sentenced to 66 years to life for violent sex offenses he committed at age 17 is not entitled to youth offender parole consideration under Penal Code section 3051 on federal and California constitutional equal protection grounds.The Court of Appeal found that a rational basis exists for treating one strike offenders such as defendant differently from other youthful offenders entitled to the benefit of the statute, applying the reasoning and analysis of the court in People v. Williams (2020) 47 Cal.App.5th 475, review granted July 22, 2020, S262229. In this case, defendant was convicted of four counts of forcible rape, one count of forcible oral copulation, and one count of first degree robbery. The court explained that defendant is not similarly situated to those who do not commit violent sex crimes, and his exclusion from youth offender parole consideration is rationally related to a legitimate penal interest. View "People v. Moseley" on Justia Law

The Supreme Judicial Court held that 120 Code Mass. Regs. 200.08(3)(c) (regulation), which concerns parole eligibility for inmates sentenced to a prison term that runs consecutive to a life sentence, is contrary to the plain terms of the statutory framework governing parole and is thus invalid.Plaintiffs, two inmates who were serving life sentences for murders committed when they were juveniles, sought declaratory relief invalidating the regulation. The superior court granted summary judgment in favor of the parole board, finding the regulation to be valid. The Supreme Judicial Court reversed, holding that by exempting sentences consecutive to a life sentence from the process often referred to as the "aggregation rule," the regulation contravenes the plain meaning of Mass. Gen. Laws ch. 127, 130 and 133. View "Dinkins v. Massachusetts Parole Board" on Justia Law