Justia Juvenile Law Opinion Summaries

The defendant was convicted of eight sex crimes involving three juvenile girls, including his stepdaughter and two other children in the household. The most serious incident occurred in December 2016, when a six-year-old girl suffered a severe vaginal injury while in the defendant’s care, leading to hospitalization and subsequent disclosure of sexual abuse. Over the following years, two other girls reported that the defendant had also sexually abused them on multiple occasions, with one describing repeated acts of molestation occurring regularly over a period of time.The Sonoma County Superior Court jury found the defendant guilty on all counts, including multiple counts of sexual intercourse or lewd acts with a child under 14, and found true several sentencing enhancements. The defendant appealed, challenging two of the convictions related to one victim. He argued that the prosecution relied on the same testimony to support both charged and uncharged offenses, and that the jury instruction regarding uncharged sex offenses (CALCRIM No. 1191A) improperly lowered the prosecution’s burden of proof and confused the jury. He also raised an alternative claim of ineffective assistance of counsel for failing to object to the instruction.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that, although the same testimony was used to support both charged and uncharged offenses and the instructions could have been clearer, any potential instructional error was harmless beyond a reasonable doubt. The court found that the jury was properly instructed that each charged offense had to be proven beyond a reasonable doubt, and that the evidence supporting the convictions was substantial. The judgment of conviction was affirmed. View "People v. Dejesus-Galindo" on Justia Law

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law

A 13-year-old juvenile pleaded guilty to fourth degree assault and was placed under community supervision with several conditions, including abstaining from alcohol. Over several months, she repeatedly violated these conditions, including using alcohol, failing to report to her probation officer, and leaving her home. The State sought multiple bench warrants, ultimately arguing that her actions, including a suicide attempt while intoxicated, posed a serious threat to public safety. The juvenile court issued a bench warrant, finding that her conduct met the “serious threat to public safety” standard required by a court rule, JuCR 7.16.On appeal, the Washington Court of Appeals determined that the facts did not meet JuCR 7.16’s “serious threat to public safety” requirement, as the connection between her actions and a threat to public safety was too attenuated. However, the appellate court also held that JuCR 7.16 irreconcilably conflicted with RCW 13.40.040, a statute with less restrictive prerequisites for issuing juvenile arrest warrants. The majority concluded that JuCR 7.16 was substantive, not procedural, and therefore invalid because it conflicted with the legislature’s authority over substantive law. A dissenting judge disagreed, viewing the rule as procedural.The Supreme Court of the State of Washington reversed the Court of Appeals. It held that JuCR 7.16 is a procedural rule governing the issuance of warrants and falls within the court’s inherent, constitutional, and statutory authority. The court further held that JuCR 7.16 and RCW 13.40.040 can be harmonized, requiring courts to satisfy both sets of prerequisites before issuing a warrant. The court also clarified that “serious threat to public safety” under JuCR 7.16 does not include threats solely to the juvenile’s own safety. The Supreme Court declined to recuse itself from the case. View "State v. A.M.W." on Justia Law

The defendant was charged with several offenses, including attempted gross sexual imposition, gross sexual imposition, two counts of child neglect, and indecent exposure, based on allegations that he forced two minor children to consume Nyquil and, in one case, marijuana/THC gummies. The State alleged these actions constituted child neglect under North Dakota law. The case proceeded to a jury trial, where the defendant moved for acquittal at the close of the State’s case and again after the defense rested, but both motions were denied. The jury found the defendant guilty on the two counts of child neglect, and the district court entered judgments of acquittal on the remaining charges.The District Court of Williams County, Northwest Judicial District, presided over the trial and sentencing. On appeal to the Supreme Court of North Dakota, the defendant argued that the evidence was insufficient to support the child neglect convictions, contending that the statute criminalizes only omissions, not affirmative acts, and that his conduct, if criminal, would constitute child abuse rather than neglect. He also challenged the admission of jail call recordings, arguing improper authentication and hearsay.The Supreme Court of North Dakota held that the child neglect statute is not limited to omissions but can include affirmative acts that constitute a willful failure to provide proper parental care. The court found sufficient evidence supported the jury’s verdict and that the district court did not err in denying the motions for acquittal. Regarding the jail call recordings, the court concluded that the State provided sufficient evidence to authenticate the recordings and that the defendant’s failure to object on hearsay grounds at trial precluded reversal on that basis. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Hendricks" on Justia Law

A sixteen-year-old youth admitted to sexually assaulting his two younger half-siblings, ages six and seven, over a period spanning late 2021 to early 2023. The abuse involved coercion through threats of withholding privileges and included both physical and digital penetration. The youth was charged with multiple counts of felony sexual assault and incest, and a more serious charge was dismissed as part of a plea agreement. A psychosexual evaluation found the youth to be at moderate risk of reoffending and recommended against requiring registration as a sexual offender, suggesting that avoiding registration would better support his rehabilitation. The victims’ family members and therapist, however, advocated for registration due to the trauma suffered.The Fourth Judicial District Court, Missoula County, reviewed the psychosexual evaluation, probation officer’s report, and victim impact statements. The court designated the youth as a Level 2 Sexual Offender, committed him to a youth correctional facility until age 18, and placed him on probation until age 21. Despite recommendations against registration from the evaluator and probation officer, the court ordered the youth to register as a sexual offender for life, citing the need to protect the public given the nature of the offenses and the youth’s position of trust.On appeal, the Supreme Court of the State of Montana considered whether the District Court abused its discretion in imposing the registration requirement. The Supreme Court held that the District Court acted within its discretion, finding substantial evidence supported the decision and that the court properly considered the statutory requirements and public interest. The Supreme Court affirmed the District Court’s order requiring the youth to register as a sexual offender. View "In re B.J.B." on Justia Law

The case concerns Kenneth Robinson, who was convicted of malice murder and other offenses related to the shooting death of Devontae Jones and the aggravated assault of Charmisa Witherspoon. The evidence showed that Robinson, age fourteen at the time, was involved with the 9 Trey Bloods gang. After a gang member, Jesus Cintron, disappeared, the gang’s leader plotted to kill Witherspoon and her son, fearing Witherspoon would cooperate with law enforcement. Robinson and other gang members went to Witherspoon’s house, where Robinson participated in the assault. Witherspoon escaped, but her son was killed. Robinson was tried alongside several co-defendants.The Superior Court of Fulton County granted Robinson a directed verdict on several counts and dead docketed one count, later nol prossed. The jury found Robinson guilty on the remaining counts except one. He was sentenced to life plus forty-five consecutive years. Robinson filed a motion for new trial, which was denied. His initial appeal was dismissed due to a pending count, but after that count was nol prossed, he filed an amended notice of appeal.The Supreme Court of Georgia reviewed the case. Robinson argued that his trial counsel was ineffective for failing to communicate a plea offer, that his sentencing procedure violated constitutional and statutory rights, that the trial court misunderstood its sentencing discretion, and that certain counts should have merged for sentencing. The court held that trial counsel did communicate the plea offer, so there was no deficient performance. The court also found no constitutional or statutory violation in the sentencing procedure, noting that neither Robinson nor his counsel objected or requested to be heard. Claims regarding the trial court’s sentencing discretion and merger of counts were found to be waived or without merit. The Supreme Court of Georgia affirmed Robinson’s convictions. View "ROBINSON v. THE STATE" on Justia Law

A child was born in Connecticut in July 2024 to parents who both resided in Connecticut at the time of the birth. The mother, who had previously lived in Massachusetts and had a long history with the Massachusetts Department of Children and Families (DCF), moved to Connecticut several months before the birth, enrolling in a Connecticut healthcare program and living in a domestic violence shelter there. The father had also been living in Connecticut. The Massachusetts DCF, concerned about the child’s welfare due to the mother’s history and a recent domestic violence incident involving the father, arranged to take emergency custody of the child at the Connecticut hospital immediately after birth.Two days after the child’s birth, the Massachusetts DCF filed a care and protection petition in the Hampden County Division of the Juvenile Court Department, seeking temporary custody. The Juvenile Court granted temporary custody to the department without determining the basis for jurisdiction. Later, after hearings, a Juvenile Court judge found that Massachusetts had default jurisdiction under the Massachusetts Child Custody Jurisdiction Act (MCCJA), and subsequently, after joint conferences with a Connecticut judge, concluded that Massachusetts was the appropriate forum because Connecticut had declined jurisdiction. The parents and the child sought interlocutory appeal, and the Appeals Court allowed it. The Supreme Judicial Court of Massachusetts then transferred the case on its own initiative.The Supreme Judicial Court of Massachusetts held that the Juvenile Court lacked jurisdiction under the MCCJA because Connecticut was the child’s “home state,” as the child lived there from birth with the parents. The Court found that Massachusetts did not have default, emergency, or appropriate forum jurisdiction, as Connecticut had not declined jurisdiction before the Massachusetts court issued custody orders. The Supreme Judicial Court remanded the case for dismissal due to lack of jurisdiction. View "Care and Protection of Faraj" on Justia Law

Two minor children were removed from their parents’ care after their father was incarcerated for felony convictions and their mother was unable to care for them due to drug addiction and homelessness. The children were placed in foster care after the Kansas Department for Children and Families determined that neither parent could provide adequate care. The father, while incarcerated, had limited contact with the children and did not complete most tasks in the reintegration plan, citing the constraints of his imprisonment. The children exhibited significant behavioral and emotional issues while in foster care, and potential placement with a maternal grandmother was being considered.The Leavenworth County District Court adjudicated the children as in need of care and, after 16 months without progress toward reintegration, found both parents unfit. The court based its finding regarding the father on his felony conviction and imprisonment, failure of reasonable efforts by agencies to rehabilitate the family, and failure to carry out a reasonable reintegration plan. The court concluded that the father’s unfitness was unlikely to change in the foreseeable future and that termination of parental rights was in the children’s best interests, given their need for permanency and the availability of a stable placement with a relative.The Kansas Court of Appeals affirmed the district court’s decision, focusing primarily on the father’s imprisonment as a statutory ground for unfitness and agreeing that the unfitness was unlikely to change soon. The Supreme Court of the State of Kansas reviewed the case and held that clear and convincing evidence supported the findings of unfitness and that the conduct or condition rendering the father unable to care for his children was unlikely to change in the foreseeable future. The court also held that the district court did not abuse its discretion in determining that termination was in the children’s best interests. The judgments of both lower courts were affirmed. View "In re K.W.D." on Justia Law

Eric Skeens was convicted in Indiana of five counts of child molesting, based almost entirely on the detailed testimony of the child victim, K.W. There was no physical evidence presented at trial, but the prosecution relied on K.W.’s account, as well as supporting testimony from her mother, a school counselor, a therapist, and a sexual assault nurse who explained the absence of physical evidence. During closing arguments, Skeens’s attorney made a statement to the jury, “I believe her,” referring to K.W., which Skeens later argued constituted ineffective assistance of counsel.After his conviction, Skeens appealed to the Indiana Court of Appeals, which affirmed the conviction and found that the attorney’s statement did not prejudice the outcome, given the strength and detail of K.W.’s testimony. The Indiana Supreme Court declined to review the case, and Skeens’s subsequent state post-conviction and federal habeas petitions were also denied. The United States District Court for the Northern District of Indiana denied relief, concluding that Skeens had not shown the state court’s decision was unreasonable under federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case, applying the deferential standards required by the Antiterrorism and Effective Death Penalty Act and Strickland v. Washington. The court held that the Indiana Court of Appeals did not unreasonably determine the facts or unreasonably apply the Strickland standard when it concluded that there was no reasonable probability the outcome would have been different absent the attorney’s statement. The Seventh Circuit therefore affirmed the district court’s denial of Skeens’s habeas petition. View "Skeens v Neal" on Justia Law

In October 2021, five children were removed from their home under a protective custody warrant and placed into the temporary custody of San Bernardino County Children and Family Services (the Department). Dependency petitions were filed for all five children. At the detention hearing, the mother denied Indian ancestry, and the father of two of the children also denied Indian ancestry but indicated potential Indian heritage on an ICWA form. The juvenile court found ICWA did not apply and took jurisdiction over the children, removing them from parental custody and ordering reunification services for the mother.The mother appealed, arguing the Department failed to fulfill its duty to inquire about the children's potential Indian ancestry from extended family members, as required by former section 224.2, subdivision (b). The Court of Appeal held that the extended-family inquiry duty did not apply because the children were placed into temporary custody pursuant to a warrant under section 340, not section 306, and thus rejected the mother's argument.The Supreme Court of California reviewed the case to resolve the conflict regarding the scope of the initial inquiry duty under former section 224.2. The court concluded that the county welfare department has an extended-family inquiry duty in all cases where a child is placed into temporary custody, regardless of whether the child was removed from the home with or without a warrant. The court held that Assembly Bill 81, which clarified this duty, applies retroactively as it merely clarified existing law.The Supreme Court of California reversed the judgment of the Court of Appeal and remanded the matter to the juvenile court for compliance with the inquiry requirements of section 224.2. If the juvenile court finds the inquiry duty has been satisfied and ICWA does not apply, it shall reinstate the jurisdiction and disposition order. If ICWA applies, the court shall proceed in conformity with ICWA and California implementing provisions. View "In re Ja. O." on Justia Law