Justia Juvenile Law Opinion Summaries

In November 2016, D.J., then 15 years old, was involved in a marijuana transaction that resulted in the shooting death of J.S. The State charged D.J. with felony murder, aggravated robbery, and possession of marijuana. D.J. agreed to plead no contest in exchange for the case being designated as an extended jurisdiction juvenile prosecution (EJJP) rather than being tried as an adult. The court sentenced D.J. to a juvenile correctional facility until he was 22 years, 6 months old, with an adult sentence of life without parole for 25 years for the felony murder count, among other penalties, stayed as long as D.J. complied with his juvenile sentence.In October 2021, D.J. was released on conditional release but was later found in a vehicle with firearms and marijuana, and in July 2022, he was caught driving without a license and possessing marijuana. The State moved to revoke D.J.'s juvenile sentence, and the district court found that D.J. had violated the conditions of his juvenile sentence by possessing firearms and marijuana and eluding law enforcement.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the revocation of D.J.'s juvenile sentence. The court also held that under K.S.A. 38-2364, the district court was required to revoke the juvenile sentence and impose the adult sentence upon finding a violation of the juvenile sentence. The court rejected D.J.'s arguments that the district court had discretion to continue the stay of the adult sentence and that the district court could modify the adult sentence under K.S.A. 22-3716.The court also dismissed D.J.'s constitutional proportionality claims, stating that case-specific challenges could not be raised for the first time on appeal and that D.J. failed to comply with Supreme Court Rule 6.02(a)(5) for his categorical challenge. Finally, the court declined to review D.J.'s ineffective assistance of counsel claim due to the lack of a Van Cleave hearing and insufficient factual development in the record. View "In re D.J. " on Justia Law

The Department of Health and Human Services (DHHS) petitioned the Lenawee Circuit Court, Family Division, to take jurisdiction over two minor children, CB and ME, and terminate the parental rights of their mother after CB alleged sexual abuse by two of the mother's male friends. CB claimed the mother was aware of the abuse and allowed it in exchange for drugs. The court authorized the petition, suspended the mother's parenting time, and ordered the children to remain with their father. At the combined adjudication and termination hearing, CB testified about the abuse, and the court found her testimony credible, concluding that grounds for adjudication and termination existed.The trial court terminated the mother's parental rights under MCL 712A.19b(3)(b)(i), (b)(ii), and (j), finding that termination was in the children's best interests. The mother appealed, and the Michigan Court of Appeals reversed and remanded, concluding that aggravated circumstances were not present under MCL 722.638(1)(a)(ii) because the mother was not the perpetrator of the criminal sexual conduct. The court also found that the trial court erred by not advising the mother of her right to appeal the removal order.The Michigan Supreme Court reviewed the case and held that under MCL 712A.19a(2)(a), DHHS is not required to make reasonable efforts to reunify the family when there is a judicial determination of aggravated circumstances as provided in MCL 722.638(1) and (2). The court concluded that the mother subjected CB to aggravated circumstances by facilitating criminal sexual conduct involving penetration, even though she did not personally commit the act. The court also found that the trial court's failure to advise the mother of her right to appeal the removal order was plain error but did not affect her substantial rights. The Supreme Court reversed the Court of Appeals' judgment and reinstated the trial court's order terminating the mother's parental rights. View "In Re Barber/Espinoza Minors" on Justia Law

Justin J. (Father) appealed a jurisdiction finding and disposition order declaring his children, Hunter V. and B.V., dependents of the juvenile court. The court sustained a petition under Welfare and Institutions Code section 300, subdivisions (b)(1) and (j), alleging the children's mother had a history of substance abuse and left the children without proper care. The petition also alleged Father had an extensive criminal history and was incarcerated, which placed the children at risk.The Los Angeles County Superior Court held a detention hearing where neither parent was present. The court detained the children and ordered monitored visitation for both parents. At the jurisdiction hearing, the court amended the petition to allege Father was unable to parent due to his incarceration and inability to make an appropriate plan for the children. The court sustained the amended allegations and proceeded with the disposition hearing, declaring the children dependents of the court and ordering reunification services for both parents.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court found that the juvenile court violated Father's due process rights by failing to provide notice of the amended allegations, which were based on a different set of facts and legal theory from the initial petition. The court also violated Father's statutory right to be present at the jurisdiction hearing, as required by Penal Code section 2625, subdivision (d). The appellate court applied the Chapman standard for federal constitutional error and concluded the error was not harmless beyond a reasonable doubt. Consequently, the court reversed the jurisdiction finding and disposition order as to Father and remanded the case for further proceedings with Father present unless he waives his right to be present. View "In re Hunter V." on Justia Law

The Office of Children’s Services (OCS) removed two Indian children from their home after finding their parents intoxicated and unable to care for them. The superior court adjudicated the children as being in need of aid, and the children’s tribe intervened. The children’s father moved to another state and, after initially failing to engage with OCS, eventually completed all case plan requirements. OCS then sought to place the children with their father through the Interstate Compact for the Placement of Children (ICPC), but the other state denied approval. Despite this, OCS sought permission from the superior court to release custody to the father while he was temporarily in Alaska.The superior court found that the ICPC was inapplicable to a release of custody to a parent under AS 47.14.100(p) and granted OCS’s request, dismissing the case. OCS released custody to the father before he left Alaska. The Native Village of Saint Michael appealed, arguing that the ICPC should apply and that the superior court failed to make adequate best interest findings.The Supreme Court of the State of Alaska reviewed the case and concluded that when OCS properly releases custody of a child to a parent under AS 47.14.100(p), the requirements of the ICPC do not apply, even if the parent plans to subsequently transport the child to another state. The court affirmed the superior court’s decision that the ICPC was inapplicable under the circumstances and that the other state’s approval was not required for placement with the father. The court also affirmed the dismissal of the case. View "Native Village of Saint Michael v. State" on Justia Law

A juvenile, D.W., was charged with child molestation and dissemination of material harmful to minors. During the initial hearing, the juvenile court allowed D.W.'s counsel to waive a formal advisement of rights without personally confirming with D.W. if he agreed to the waiver. After a fact-finding hearing, D.W. was adjudicated delinquent. D.W. appealed, arguing that the juvenile court erred by not providing a formal advisement of rights and that his counsel's waiver was invalid because it was not confirmed that D.W. knowingly and voluntarily joined the waiver.The Marion Superior Court adjudicated D.W. delinquent, and the Indiana Court of Appeals affirmed the decision. The Court of Appeals found that the delinquency petition provided sufficient notice of the charges and that any errors in the advisement of rights did not rise to the level of fundamental error. The court also noted that D.W. exercised his constitutional rights during the proceedings.The Indiana Supreme Court reviewed the case and agreed that the juvenile court erred by not providing a formal advisement of rights and that the waiver by D.W.'s counsel was invalid because the court did not personally confirm the waiver with D.W. However, the Supreme Court found the error to be harmless because D.W.'s substantial rights were not affected. D.W. was represented by counsel, exercised his constitutional rights, and there was no indication that the lack of formal advisement impacted the outcome of the case. Therefore, the Indiana Supreme Court affirmed the juvenile court's delinquency adjudication. View "D.W. v. State" on Justia Law

A thirteen-year-old girl, D.C., reported to her stepmother that her stepfather, Edgar Rene Garcia-Limon, had sexually abused her over several years, beginning when she was about four and continuing until she was eleven. During the investigation, D.C. described multiple incidents of abuse, and Garcia-Limon admitted to law enforcement and his wife that he had sexually touched D.C. on several occasions. Law enforcement also found firearms in the home, leading to additional charges.The United States District Court for the Eastern District of Oklahoma indicted Garcia-Limon on four counts: felon in possession of a firearm, aggravated sexual abuse of a minor in Indian Country, abusive sexual contact in Indian Country, and illegal reentry. Garcia-Limon challenged the sufficiency of the indictment for the sexual abuse counts, arguing that the eight-year date range was too broad and that the counts improperly charged a scheme rather than specific acts. The district court denied his motions, finding that the indictment properly charged a scheme of abuse and that the counts were not constitutionally defective or duplicitous. At trial, the jury found Garcia-Limon guilty on all counts, and he was sentenced to concurrent terms, including life sentences for the sexual abuse counts.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the indictment was constitutionally sufficient, whether the statutes allowed charging a scheme of abuse, whether the indictment was duplicitous, and whether there was a constructive amendment at trial. The court held that the indictment met constitutional requirements, that the statutes permitted charging a scheme of repeated, similar acts in a single count, and that there was no unconstitutional duplicity or constructive amendment. The Tenth Circuit affirmed Garcia-Limon’s convictions on the challenged counts. View "United States v. Garcia-Limon" on Justia Law

B.J.S., a Native American born in 2004, was charged with multiple acts of aggravated sexual abuse against his younger sister L.S. between August 2019 and June 2022, when he was 15 to 17 years old. The government filed a juvenile information and moved to transfer the proceedings to adult court. The charges included causing L.S. to engage in sexual acts by force, engaging in sexual acts with L.S. under 12, and causing sexual contact with L.S. under 12 with intent to abuse, humiliate, harass, degrade, or arouse sexual desire.The United States District Court for the District of North Dakota granted the government's motion to transfer the case to adult court. B.J.S. moved to dismiss the transfer motion, arguing that the charges did not qualify as "crimes of violence" under 18 U.S.C. § 5032. The district court denied his motion and granted the transfer after an evidentiary hearing. B.J.S. appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the charges under 18 U.S.C. §§ 2241(a), 2241(c), and 2244(a)(5) did not qualify as "crimes of violence" under 18 U.S.C. § 16(a). The court applied the categorical approach, considering only the statutory elements of the offenses. It found that § 2241(a) was overbroad and indivisible, covering more conduct than § 16(a). Similarly, § 2241(c) and § 2244(a)(5) did not require the use, attempted use, or threatened use of physical force against another person. Consequently, the court concluded that none of the charges met the definition of a "crime of violence" for purposes of § 5032 permissive transfer.The Eighth Circuit reversed the district court's decision and remanded the case, determining that the transfer to adult court was not justified. View "United States v. B.J.S." on Justia Law

J.W., a 14-year-old, and two other juveniles were involved in an incident where one of the boys exploded a large firework inside a vacant trailer home, causing significant fire and smoke damage. J.W. initially lied to the police about who caused the fire to protect the other juveniles. He later admitted to a juvenile delinquency petition alleging accessory to a crime. The circuit court ordered J.W. and another juvenile to pay restitution of approximately $15,000 for the damage.The Circuit Court of the Seventh Judicial Circuit in Pennington County adjudicated J.W. as a delinquent child and placed him on probation. The court held a restitution hearing and ordered J.W. to pay restitution, finding that the legislative amendments to the juvenile statutes did not require a causal connection between the damages and J.W.'s criminal act. The court determined that the restitution served a rehabilitative purpose and found no credible evidence that the restitution order would cause J.W. serious hardship.The Supreme Court of the State of South Dakota reviewed the case. The court held that the legislative amendments to the juvenile restitution statutes now require a causal connection between the juvenile's criminal act and the victim's damages, similar to adult restitution cases. The court found that J.W.'s act of lying to the police occurred after the damage was done and was not causally connected to the fire damage. Therefore, the court reversed and vacated the circuit court's restitution order, concluding that J.W. was not liable for restitution as the damage did not occur as a result of his criminal act. View "Interest Of J.W." on Justia Law

James Russell Trimble, who was convicted of first-degree murder and other crimes committed when he was 17 years old, filed a motion for a reduction of his sentence under Maryland's Juvenile Restoration Act (JUVRA). This act allows individuals convicted as minors and who have served at least 20 years to seek a sentence reduction. Trimble argued that his age at the time of the offense and his rehabilitation efforts warranted a reduced sentence.The Circuit Court for Baltimore County denied Trimble's motion, finding that his age at the time of the crime did not support a sentence reduction, and that he continued to pose a danger to the public. The court also did not credit the testimony of Trimble's expert, who argued that Trimble's antisocial personality disorder (ASPD) had remitted. The court emphasized the brutal nature of the crime and the lasting impact on the victim's family.The Appellate Court of Maryland affirmed the circuit court's decision, holding that the circuit court did not abuse its discretion. The appellate court found that the circuit court had adequately considered all the required factors under JUVRA, including Trimble's age, rehabilitation efforts, and expert testimony. The appellate court also noted that the circuit court was not required to give special consideration to any particular factor, including rehabilitation.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The court held that under JUVRA, the circuit court has broad discretion to determine whether an individual is a danger to the public and whether the interests of justice will be served by a reduced sentence. The court is required to consider ten enumerated factors but is not required to give special consideration to any particular factor. The Supreme Court found that the circuit court had properly exercised its discretion in denying Trimble's motion for a reduced sentence. View "Trimble v. State" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law