Justia Juvenile Law Opinion Summaries

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

J.D., a juvenile defendant, faced multiple charges and challenged his competency to proceed. The juvenile court ordered the Department of Human Services (the "Department") to conduct an in-custody competency evaluation, which found J.D. incompetent but restorable. The court then ordered outpatient restoration services. Subsequently, J.D. was charged with additional delinquent acts, and the court extended its incompetency finding to all cases, ordering the Department to oversee inpatient restoration services and provide periodic status reports.The Department later reassessed J.D.'s competency without a court order and concluded that he had been restored to competency. J.D. moved to strike the Department's report, arguing that the Department lacked the authority to conduct the evaluation without a court order under section 19-2.5-704(2)(c). The juvenile court denied the motion, finding that the Department had the authority to conduct restoration evaluations as part of its responsibility to provide restoration services.The Supreme Court of Colorado reviewed the case and held that the Department's responsibility to provide restoration services under section 19-2.5-704(2)(b) includes the authority to perform restoration evaluations without a court order. The court concluded that restoration evaluations are part of the "services necessary to competency restoration." Therefore, the juvenile court properly accepted and considered the Department's evaluation in finding J.D. restored to competency. The order to show cause was discharged. View "In re People ex rel. J.D." on Justia Law

The Department of Health and Human Services (DHHS) filed a petition in the Wayne Circuit Court to take jurisdiction over a minor, DVL, from the respondent-mother under MCL 712A.2(b)(1) or (2). DVL, who had a history of mental illness, was taken to St. John Hospital after attempting to start a fire and threatening suicide. The hospital cleared DVL for discharge without treatment, recommending intensive outpatient services. The respondent refused to pick up DVL, citing safety concerns for her other children and herself. The trial court denied the petition, finding no evidence of neglect or abuse by the respondent, who had made numerous efforts to seek help for DVL.The Court of Appeals reversed the trial court's decision in a split unpublished decision, holding that jurisdiction was appropriate under both MCL 712A.2(b)(1) and (2). The majority found that the respondent's actions rendered the home environment dangerous for DVL and her other children, making it statutorily unfit. The respondent sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court, in lieu of granting leave to appeal, held that the trial court did not clearly err by refusing to take jurisdiction of DVL under MCL 712A.2(b)(1) or (2). The Court found that the respondent was not "able" to provide necessary care and support for DVL at home due to the danger he posed to himself and others. Additionally, the respondent's refusal to take DVL home was not considered neglectful, as she acted as a reasonably prudent person would under the circumstances. The Court reversed the Court of Appeals decision and remanded the case to the trial court for reinstatement of its order denying DHHS's petition. View "In Re Lange" on Justia Law

A.T. was born in May 2024 and tested positive for amphetamine and methamphetamine, as did her mother, M.T. The mother admitted to drug addiction and using methamphetamine throughout her pregnancy. The San Diego County Health and Human Services Agency (Agency) was notified, and A.T. was placed with a relative caregiver, Gloria T. The father, W.M., had a history of domestic violence and substance abuse issues, and had previously been involved in dependency proceedings for his other children, Y.M. and J.G.The Superior Court of San Diego County found that A.T. was a dependent child under section 300 of the Welfare and Institutions Code and ordered her removal from her mother's custody. The court also found that placing A.T. with her father would be detrimental to her well-being, citing his history of domestic violence, ongoing relationship with the mother, and lack of cooperation with the Agency.The father appealed, arguing that section 361, subdivision (d) should apply, which requires a higher standard of proof for removal, and that there was no clear and convincing evidence to support the finding of detriment. The Agency argued that section 361.2, subdivision (a) applied because the father did not have physical custody of A.T. at the time of disposition and sought to assume custody.The California Court of Appeal, Fourth Appellate District, Division One, concluded that section 361.2 applied because the father was the noncustodial parent seeking custody. The court found clear and convincing evidence supporting the juvenile court's finding that placing A.T. with the father would be detrimental to her safety and well-being. The court affirmed the juvenile court's dispositional order, maintaining A.T.'s placement with the relative caregiver and granting the father liberal unsupervised visitation. View "In re A.T." on Justia Law

A minor, J.H.-M., was adjudicated guilty of second-degree rape by forcible compulsion. The juvenile court imposed a Special Sex Offender Disposition Alternative, including 30-40 weeks of confinement, suspended for a 24-month supervision period. Conditions of supervision included maintaining employment or school enrollment, compliance with treatment requirements, and registration. Although the sentencing judge verbally declined to impose a condition prohibiting sexually explicit material, the written order included this prohibition.J.H.-M. appealed to the Court of Appeals, arguing that the condition prohibiting sexually explicit material was unconstitutionally vague and overbroad. The State initially moved to concede error based on the judge's verbal statement, but Division One of the Court of Appeals denied the motion and directed briefing on the merits. The Court of Appeals affirmed the condition, concluding it was not unconstitutionally vague or overbroad, distinguishing it from a similar condition in a previous case, State v. Padilla.The Supreme Court of the State of Washington reviewed the case. The court held that the condition prohibiting sexually explicit material was not unconstitutionally vague. The court reasoned that the term "sexually explicit conduct" was sufficiently defined by prior case law and the referenced statute, former RCW 9.68A.011(4), which provided specific examples of prohibited acts. The court concluded that the condition provided adequate notice of proscribed conduct and ascertainable standards to prevent arbitrary enforcement. The Supreme Court affirmed the imposition of the condition and the decision of the Court of Appeals. View "State v. J.H.-M." on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law

Ramiro Munoz, a member of a criminal street gang, was convicted in 2008 of first-degree murder and shooting at an occupied motor vehicle, with firearm and gang allegations found true. Munoz, who was 15 years old at the time of the crime, was sentenced to 50 years to life in prison. In 2023, Munoz filed a petition for recall and resentencing under Penal Code section 1170, subdivision (d)(1), arguing that his sentence was the functional equivalent of life without the possibility of parole, making him eligible for relief under the statute.The Superior Court of Los Angeles County denied Munoz's petition, stating that he would be eligible for parole under section 3051 in 2029, when he would be 39 years old. Munoz appealed the decision, and the case was reviewed by the Court of Appeal of the State of California, Second Appellate District, Division Seven.The Court of Appeal affirmed the superior court's decision, holding that Munoz's sentence of 50 years to life is not the functional equivalent of life without the possibility of parole. The court concluded that section 1170, subdivision (d)(1), applies only to juvenile offenders explicitly sentenced to life without the possibility of parole and does not extend to those with lengthy sentences that may be considered de facto life without parole. The court also noted that Munoz would have a realistic opportunity to obtain release from prison during his expected lifetime, distinguishing his case from others with significantly longer sentences. View "People v. Munoz" on Justia Law

Cynthia Maldonado and Martha Amaro, who lived on both sides of the Oklahoma-Kansas border and in Mexico, appealed a trial court's order that Oklahoma had jurisdiction over a juvenile deprived proceeding under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The trial court found that Maldonado's child, L.A., had resided in Oklahoma for six months preceding the commencement of the proceeding, making Oklahoma the child's home state. The court also adjudicated the children deprived as to Maldonado.The Texas County District Court of Oklahoma ordered that N.A. and L.A. be taken into emergency custody by the Oklahoma Department of Human Services (OKDHS) after Maldonado and N.A. tested positive for methamphetamine at birth. Maldonado filed a motion arguing that Oklahoma did not have jurisdiction under the UCCJEA, claiming that Mexico and Kansas were the children's home states. The State argued that Oklahoma had jurisdiction under the Oklahoma Children's Code. The trial court found that L.A. had lived in Oklahoma for six months before the proceeding and adjudicated the children deprived.The Supreme Court of the State of Oklahoma reviewed the case and affirmed the trial court's findings. The court held that the Oklahoma district court had subject matter jurisdiction over the juvenile deprived proceeding and that the UCCJEA applied to such proceedings. The court found that the trial court's determination that L.A. had resided in Oklahoma for six months preceding the proceeding was not clearly erroneous. The court also affirmed the trial court's order adjudicating the children deprived as to Maldonado, finding competent evidence to support the order. The appeal was not considered moot due to ongoing collateral consequences. View "IN RE: N.A.; STATE OF OKLAHOMA vs MALDONADO" on Justia Law

E.M., a fifteen-year-old, was arrested for allegedly killing S.A. and wounding four others in a racially motivated drive-by shooting. The State charged E.M. with multiple felonies, including murder, in juvenile court and sought to transfer the case to district court.The juvenile court held a preliminary hearing where eight witnesses testified. The court found probable cause that E.M. was a principal actor in the murder and analyzed whether retaining jurisdiction was contrary to the best interests of E.M. and the public. The court considered the seriousness of the crime, the aggressive and premeditated nature of the offense, E.M.'s traumatic background, lack of prior criminal record, and the likelihood of rehabilitation. The court noted E.M.'s difficult childhood, marked by extreme trauma, and his progress in detention but also highlighted incidents of racially motivated violence. Ultimately, the court concluded that transferring E.M. to district court was appropriate.The Utah Supreme Court reviewed whether the juvenile court abused its discretion in transferring E.M.'s case. The court emphasized that the Transfer Statute requires a holistic approach, considering all relevant circumstances surrounding the qualifying offense. The court found that the juvenile court appropriately considered the context of the crime, including non-qualifying offenses, to assess the seriousness and premeditated nature of the offense. The court also held that the juvenile court did not err in weighing E.M.'s trauma history as a factor that could impact the likelihood of rehabilitation.The Utah Supreme Court upheld the juvenile court's decision, finding no abuse of discretion in the transfer of E.M.'s case to district court, concluding that it was in the best interests of both E.M. and the public. View "In re E.M." on Justia Law

In this case, the State charged an adult with capital murder, alleging he was sixteen at the time of the offense. The juvenile court found it was not practicable to proceed before the adult turned eighteen because the State lacked probable cause to arrest him at that time. The court of appeals reversed and dismissed the case, holding that probable cause existed to arrest him before he turned eighteen, thus the State failed to establish it was impracticable to proceed.The juvenile court granted the State’s motion to transfer the case to adult criminal court, combining elements of two statutory good cause alternatives. The court of appeals vacated the order and dismissed the case for want of jurisdiction, noting the juvenile court’s findings were difficult to decipher and lacked a “due diligence” finding required by one of the statutory alternatives. The court of appeals concluded that the State had sufficient evidence to establish probable cause before the respondent turned eighteen, and the reasons for delay were not beyond the State’s control.The Supreme Court of Texas reviewed the case and largely agreed with the dissenting justice from the court of appeals. The Court held that the development of probable cause alone does not determine whether it is “practicable to proceed” with a juvenile prosecution before a person reaches adulthood. Other reasons beyond the control of the State may support such a finding. The Court found that the juvenile court erred in conflating “practicable to proceed” with the existence of probable cause and remanded the case to the juvenile court for a new transfer hearing. The Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with its opinion. View "IN THE MATTER OF J.J.T." on Justia Law