Justia Juvenile Law Opinion Summaries

The Supreme Court vacated the decision of the court of appeals affirming the determination of the juvenile court that termination of Father's parental rights was not in the child's best interest, holding that Iowa Code chapter 600A's best interest factors weigh in favor of terminating Father's parental rights.Mother petitioned for the termination of Father's parental rights due to abandonment under section 600A.8(3)(b). The juvenile court found that Father statutorily abandoned the child but denied Mother's petition based on its determination that termination was not in the child's best interest. The court of appeals affirmed. The Supreme Court vacated the court of appeals' decision and reversed the judgment of the district court, holding that the juvenile court erred in concluding that termination of Father's parental rights was not proper under chapter 600A. View "In re Interest of B.H.A." on Justia Law

The Court of Appeal reversed the trial court's order granting habeas relief to respondent under Penal Code section 3051. The People argued that the trial court wrongly found section 3051 applicable because respondent had already been granted parole on his indeterminate-term youth offense.The court held that, by the plain language of the statute, respondent was not entitled to a youth offender parole hearing at the time the statute became effective and thus was not entitled to the additional benefits afforded by the case law requiring immediate release upon parole under that statutory scheme. View "In re Howerton" on Justia Law

In 1994, 17-year-old Cristian J. Delbosque was convicted of aggravated first degree murder and received a mandatory life sentence without the possibility of release. Because he was a juvenile at the time of his offense, Delbosque was resentenced in 2016 in accordance with the Miller-fix statute and received a minimum term of 48 years without the possibility of parole. The Court of Appeals concluded that Delbosque could seek review of his sentence only through a personal restraint petition (PRP), rather than direct appeal, but nevertheless reversed his sentence, holding that the trial court's factual findings were not supported by substantial evidence. The Washington Supreme Court affirmed the Court of Appeals' holding that the sentencing court's findings were not supported by substantial evidence, thus remanding for resentencing was proper. However, the Supreme Court reversed the Court of Appeals' holding that Delbosque was not entitled to a direct appeal. View "Washington v. Delbosque" on Justia Law

J.M., born in 2010, suffered an accident when he was 10 months old. Since the accident J.M. has resided at Children’s Hospital, suffering from anoxic brain injury, epilepsy, developmental delays, and bone disorders. He has gastrostomy and tracheal tubes and is nonverbal. In 2017, the Hospital declared him medically cleared for discharge, provided that two adults be trained as caregivers. J.M.’s father had never visited him; his mother’s visits were infrequent. The Santa Clara County Department of Family and Children’s Service filed a petition alleging that his parents were unwilling and/or unable to care for him and that they had a history of substance abuse. The Department recommended permanent legal guardianship by J.M.’s grandmother, who visited J.M. regularly and with whom J.M. had a positive emotional bond. J.M.’s siblings were also in her care. Grandmother completed some but not all of the training to care for J.M.; she had no plans to obtain accessible housing. Grandmother was not seeking placement of J.M. in her home. J.M. opposed the plan, arguing that the court lacked authority to appoint grandmother as legal guardian without him being in her physical custody and that the plan was not in his best interest because it would relieve the Department of any obligation to find a less restrictive placement. The court of appeal affirmed the adoption of the Department’s recommendation. Continued residence at the hospital may not be optimal, but grandmother is committed to J.M’s best interest and supports moving him to a suitable permanent care facility should that become available. The court asked the Department to continue to look for more permanent placement, View "In re J.M." on Justia Law

Minor recorded photographs and videos on his cellular phone of consensual sexual activity between himself and Jane Doe, both under 18 years old. He later extorted money from Doe by threatening to disclose the recordings to other students at their high school. He was placed on juvenile probation after admitting to felony possession of child pornography (Pen. Code 311.11(a)) and extortion (Pen. Code 518, 520). Minor argued that a probation condition requiring him to submit all electronic devices under his control to warrantless searches by the probation department and to provide passwords necessary to access information on those devices was unconstitutionally overbroad. The California Supreme Court granted review and transferred the matter to the court of appeal for reconsideration in light of its 2019 decision, In re Ricardo P. The court of appeal again upheld the condition, noting the direct relationship between minor’s offenses and his use of an electronic device. The search condition was appropriately tailored. View "In re Q.R." on Justia Law

Before the Alaska Supreme Court in this case was a constitutional claim arising from the application of a juvenile jurisdiction waiver statute. A minor subject to the statutory provision did not testify at his waiver hearing and did not overcome the presumption enumerated in the statute; the superior court granted the State’s waiver petition. The minor appealed, contending the statutory rebuttable presumption and shifted burden of proof violated his constitutional right against self-incrimination and his constitutional due process rights. The Supreme Court explained that fundamental fairness required adopting an exclusionary rule when a minor bears the burden of rebutting the statutory presumption of being unamenable to treatment in the juvenile justice system: the minor’s testimonial evidence at the waiver hearing cannot be used as substantive evidence over the minor’s objection at any subsequent juvenile adjudication or adult criminal proceedings. View "C.D., a Minor v. State of Alaska" on Justia Law

In 1994, sixteen-and-a-half-year-old Stephen McGilberry brutally murdered four family members, including his three-year-old nephew. McGilberry premeditated and planned his crime, enlisting a younger neighbor’s help. A jury found McGilberry guilty of four counts of capital murder and sentenced him to death. But in 2005, the United States Supreme Court invalidated the death penalty for offenders who committed their capital crimes before reaching the age of eighteen. McGilberry's death sentence was vacated and he was resentenced to life without parole. In 2012, the Supreme Court held that the mandatory imposition of life without parole for crimes committed before the offender turned eighteen violated the constitutional prohibition against cruel and unusual punishment. Based on Miller v. Alabama, 567 U.S. 460 (2012), the Mississippi Supreme Court granted McGilberry permission to seek post-conviction relief from his sentence. The Mississippi Supreme Court determined that the record supported the trial court's determination that McGilberry should have been sentenced to life without parole based on his "irreparably corrupt nature," the Court found no abuse of discretion in the sentencing decision. View "McGilberry v. Mississippi" on Justia Law

The Court of Appeals vacated the disposition imposed by the district court in three juvenile matters, holding that the language in State v. J.R., 191 A.3d 1157 (Me. 2018), could be read to suggest that a court imposing an indeterminate commitment of a juvenile to a Department of Corrections facility must specify a commitment no shorter in duration than up to the juvenile's eighteenth birthday, and the trial court here may have proceeded under such a belief.In this consolidated appeal, P.S. argued that the district court abused its discretion in ordering that he be committed to Long Creek Youth Development Center for an indeterminate period up to age eighteen. The Court of Appeals noted that, once the district court decided to commit P.S. to Long Creek, it may have felt compelled to order him committed up to his eighteenth birthday. The Court then acknowledged that its language in J.R. may have contributed to such a belief and clarified that the language of J.R. does not constrain a juvenile court's discretion to impose a shorter period of indeterminate commitment than up to a juvenile's eighteenth birthday so long as that commitment is for at least one year. Accordingly, the Court vacated the judgment and remanded the matter. View "State v. P.S." on Justia Law

The Supreme Judicial Court dismissed this appeal from the judgment of a single justice of the Supreme Judicial Court denying Appellant's petition for habeas corpus, holding that this appeal presented issues that were moot and that none of the exceptions to the mootness doctrine applied.Appellant was charged with multiple juvenile offenses. The district court ordered him held at Long Creek Youth Development Center while awaiting trial. The proceedings were suspended when Appellant was determined to be incompetent to stand trial. Thereafter, Appellant filed a petition for habeas corpus seeking release from Long Creek. The single justice denied the petition. Appellant appealed. Before oral argument, Appellant was released from Long Creek and placed in a residential treatment facility, and the charges against him were dismissed. The Supreme Judicial Court dismissed the appeal, holding that the appeal was moot and that none of the exceptions to the mootness doctrine applied. View "A.I. v. State" on Justia Law

In 2011, Dominick Humphrey pled guilty to four counts of robbery (counts 2, 3, 4 and 24). For three of these counts (counts 2, 3, and 4), Humphrey admitted that he used a deadly weapon (a knife) during the commission of the offenses, and used a firearm during the commission of one of the counts (count 24). Humphrey also admitted that he was 16 years old when he committed the crimes within the meaning of Welfare and Institutions Code section 707. The trial court sentenced Humphrey to prison for 19 years. Five years into Humphrey's sentence, an employee of the California Department of Corrections and Rehabilitation (CDCR) wrote a letter to the superior court, stating that the abstract of judgment "may be in error, or incomplete[.]" In 2018, the trial court clarified that Humphrey was sentenced to 15 years for count 24 and the associated firearm enhancement and consecutive 16-month terms for counts 2, 3, and 4 (including their deadly weapon enhancements). An amended abstract of judgment was issued showing a sentence of 19 years in state prison. Thereafter, Humphrey moved to strike the firearm enhancement under Senate Bill No. 620. The trial court denied the motion because Humphrey's conviction became final before the enactment of Senate Bill No. 620. Appellate counsel filed a "Wende" brief, indicating that he had not been able to identify any arguable issue for reversal on appeal, but asked the Court of Appeal to review the record for error as Wende mandated. In reviewing the record, the Court discovered an issue to be briefed, and the parties were requested to brief whether the trial court erred in finding Humphrey ineligible for relief under Senate Bill 620 after the trial court acted to correct the abstract of judgment. Find that the trial court only made plain how the original sentence should have appeared on the amended abstract of judgment, the Court of Appeal determined Humphrey did not file a notice of appeal following the original 2011 sentence. His case became final in 2011. Senate Bill 620 took effect January 1, 2018, and Humphrey's was not entitled to retroactive application of the law to his sentence. Therefore the trial court did not err in denying his motion for resentencing. View "California v. Humphrey" on Justia Law