Justia Juvenile Law Opinion Summaries

The Supreme Court reversed Defendant's maximum 138-year sentence imposed for crimes Defendant committed as a juvenile and revised the sentence to a total sentence of eighty-eight years, holding that the 138-year sentence was inappropriate.Defendant was seventeen years old when he and two others committed murder in 1991. Defendant received an aggregate sentence of 138 years, which was the maximum possible term-of-years sentence. In 2016, Defendant filed a verified petition for post-conviction relief challenging the propriety of his sentence in light of the fact that he was a juvenile when he committed the crimes. The post-conviction court granted the petition and imposed an aggregate sixty-eight-year sentence. The Supreme Court affirmed the order granting relief and revisited its prior decision regarding the appropriateness of his sentence but revised the sentence to an aggregate term of eighty-eight years, holding (1) the doctrine of res judicata does not bar consideration of Defendant's appropriateness argument due to two major shifts in the law; and (2) Defendant's maximum term-of-years sentence imposed for crimes he committed as a juvenile was inappropriate. View "State v. Stidham" on Justia Law

Petitioner filed a petition for writ of habeas corpus, asserting that the denial of a youth offender parole hearing under Penal Code section 3051 violates his right to equal protection of the laws and constitutes cruel and unusual punishment. Petitioner, who was 21 years old at the time of the offense, was convicted of two counts of first degree murder and the jury found true the allegation that he personally used a firearm in the commission of the robbery. The jury also found true the special circumstance allegations that he committed multiple murders and murder during the commission of robbery. Petitioner was sentenced to two consecutive terms of life without the possibility of parole (LWOP).The Court of Appeal held that the amendment to section 3051 did not provide any relief to petitioner who had committed an LWOP offense after he had attained 18 years of age. The court rejected petitioner's equal protection argument, disagreeing that youth offenders sentenced to LWOP and those youth offenders sentenced to parole-eligible life terms are similarly situated with respect to the Legislature's first goal, which is to calibrate sentences in accordance with youthful offenders' diminished culpability. Furthermore, even if the court assumed petitioner is similarly situated to non-LWOP indeterminately-sentenced youth offenders aged 18 to 25, the court still would find no equal protection violation. Finally, the court held that petitioner's LWOP sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. View "In re Williams" on Justia Law

The Supreme Court vacated the juvenile court's adjudication of K.C.G. as a delinquent child for dangerously possessing a firearm, as well as its modification of K.C.G.'s probation based on that ruling, holding that the juvenile court lacked subject-matter jurisdiction.The delinquency petition here alleged that K.C.G., age sixteen, committed the offense of dangerous possession of a firearm. After a hearing, the juvenile court adjudicated him a delinquent and modified his probation. The Supreme Court vacated the adjudication, holding that the juvenile court lacked subject-matter jurisdiction because 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 Supreme Judicial Court affirmed the order of the juvenile court judge denying a juvenile's motion for relief from sex offender registration, holding that the record below was inadequate for the Court to decide the constitutional issue presented by the juvenile in this case.After the juvenile court judge denied the juvenile's motion to be relieved from his obligation to register as a sex offender the juvenile filed a petition seeking relief under Mass. Gen. Laws ch. 211, 3, arguing that requiring juveniles to register violates due process and constitutes cruel and unusual punishment based on advances in the understanding of the adolescent brain. The Supreme Judicial Court denied relief, holding (1) based on the record, the judge's determination that the juvenile should not be relieved of the obligation to register as a sex offender did not lie outside the bounds of reasonable alternatives; and (2) because of the absence of expert testimony and the failure to properly introduce the scientific studies cited in the judge's written findings, the Court did not have the necessary record to reach the constitutional issue. View "Ernest E. v. Commonwealth" on Justia Law

Kevin was charged in juvenile court with a murder he allegedly committed at age 17. A contested hearing under Welfare and Institutions Code section 707(a)(1) lasted several days. The juvenile court was presented with evidence demonstrating both the heinousness of the crime and that Kevin was raised by a loving family, had no prior criminal history, suffered little past trauma, and had no significant psychological or behavioral issues. Kevin’s juvenile hall behavior was exemplary. The juvenile court concluded that Kevin was unfit for the juvenile system and transferred him to criminal court, acknowledging “a certain tragedy” in its ruling. The court of appeal remanded for reconsideration. The court’s findings regarding section 707’s gravity and criminal-sophistication criteria are supported by substantial evidence but the court improperly evaluated section 707’s rehabilitation criterion, which it deemed its “most significant” consideration. A court cannot determine a juvenile’s rehabilitative needs based solely on the gravity of the offense, and the standard seven-year parole consideration period that applies to juveniles committed to the Department of Juvenile Justice for murder does not establish a presumptive rehabilitation period. View "Kevin P. v. Superior Court" on Justia Law

John Doe was a minor at the time the State alleged he committed two counts of lewd and lascivious conduct against a minor under the age of sixteen. Doe maintained his innocence, but argued that even if he did commit the acts alleged, the petition was time-barred under the four-year, catch-all limitation for civil actions found in Idaho Code section 5-224. The magistrate court (“juvenile court”) denied Doe's motion to dismiss the petition as untimely, and thereafter granted the State’s motion to waive Doe into adult proceedings. On intermediate appeal, the district court affirmed the decision of the juvenile court. The issue presented for the Idaho Supreme Court's review was whether proceedings under the Juvenile Corrections Act ("JCA") were "civil actions" subject to a civil statute of limitations. The Court concluded they were not, and affirmed the juvenile court, finding at JCA petition was not subject to the limitation in Idaho Code 5-224. View "Idaho v. Doe" on Justia Law

In 2009, Lopez was convicted in criminal court of murder and related charges based on his actions at age 17. In 2019, the court recalled his sentence and resentenced him under Penal Code section 1170(d)(1) to remove a gang-benefit enhancement in light of an intervening California Supreme Court decision. Before the resentencing, Lopez moved to have a juvenile court hold a transfer hearing based on 2016’s Proposition 57, which eliminated prosecutors’ ability to directly file charges against minors in criminal court; a juvenile court must first conduct a “transfer hearing” to determine whether a matter should remain in juvenile court or be transferred to adult court. The trial court denied the motion concluding that Proposition 57 did not apply despite the resentencing, because Lopez’s original sentence became final before Proposition 57 took effect.The court of appeal conditionally reversed and remanded for a juvenile court to conduct a transfer hearing. Because section 1170(d)(1) resentencing replaces the original sentence, the only sentence that matters is the new sentence, which is not final because a resentenced defendant can still obtain review from the California Supreme Court or the U.S. Supreme Court. The mere existence of the resentence makes the original sentence irrelevant. Lopez is entitled to a retroactive transfer hearing. View "People v. Lopez" on Justia Law

Consistent with People v. Elizalde (2015) 61 Cal.4th 523, the Court of Appeal held that the routine booking question exception to Miranda v. Arizona (1966) 384 U.S. 436, categorically applies to all of the core booking questions enumerated in Pennsylvania v. Muniz (1990) 496 U.S. 582, 601-602, and authorizes the admission of the defendant's answers to those specific questions into evidence without the need to assess those questions' incriminatory nature on a case-by-case basis.The Court of Appeal affirmed the juvenile adjudication in this case, holding that the trial court did not err in admitting the officer's testimony regarding the minor's answers to the booking questions about his age and date of birth, both of which fall squarely within Muniz's categories of basic biographical data. Therefore, there was sufficient evidence to support the juvenile court's adjudication. View "The People v. J.W." on Justia Law

In 2014, a jury convicted Lizarraga of second-degree murder and found that he personally used a firearm in connection with the shooting of a rival gang member. Lizarraga was 17 years old when he committed the crime. He was sentenced to 40 years to life in state prison. After his first appeal, Lizarraga filed a “Franklin” habeas corpus petition, requesting an opportunity to make a record relevant to his eventual youth offender parole hearing. The court granted the petition and set a hearing date. Lizarraga next moved for a transfer hearing in juvenile court under the Public Safety and Rehabilitation Act of 2016 (Proposition 57). The trial court denied the motion.The court of appeal affirmed, concluding that Lizarraga’s case was final when he requested the transfer hearing. Proposition 57 does not apply to final judgments. The Franklin hearing aside, Lizarraga’s case was final in June 2016, upon expiration of the time to seek U.S. Supreme Court review. The court rejected an argument that whenever a Franklin hearing is scheduled, finality is undone and all intervening changes in the law are in play. Lizarraga’s equal protection challenge is without merit. No “equal protection violation aris[es] from the timing of the effective date of a statute lessening the punishment for a particular offense.” View "People v. Lizarraga" on Justia Law

In 2002, Lusby was convicted of first-degree murder, aggravated criminal sexual assault, and home invasion and sentenced to 130 years’ imprisonment. Though he was 23 years old at the time of the trial, he was only 16 years old at the time of the offenses. After an unsuccessful direct appeal and post-conviction proceedings, he sought leave to file a successive post-conviction petition, asserting that his sentencing hearing was constitutionally inadequate under the Supreme Court’s 2012 decision, Miller v. Alabama. The Will County Circuit Court denied that motion. The appellate court reversed.The Illinois Supreme Court reinstated the trial court’s decision, denying relief. Lusby failed to show cause and prejudice such that the trial court should have granted leave to file a successive post-conviction petition. Lusby had every opportunity to present mitigating evidence but chose not to offer any. The trial court considered his youth and its attendant characteristics before concluding that his future should be spent in prison. The de facto discretionary life sentence passes constitutional muster under Miller; Lusby has not shown prejudice under 725 ILCS 5/122-1(a)(1). Miller does not require a court to use “magic words” before sentencing a juvenile defendant to life imprisonment but only requires consideration of “youth-related factors.” View "People v. Lusby" on Justia Law