Justia Juvenile Law Opinion Summaries

The case involves a minor, D.C. Jr., who was charged with murder, attempted murder, and robbery. D.C. Jr., who has an IQ of 66, was 14 years old at the time of the alleged crimes. His counsel requested a competency determination before proceeding to the certification hearing. After an initial finding of incompetency followed by competency-restoration sessions, the juvenile court declared D.C. Jr. competent to proceed. However, the court did not explicitly address the conflicting expert testimony regarding D.C. Jr.'s understanding of the proceedings and ability to assist counsel.The juvenile court certified D.C. Jr. for prosecution as an adult. The court's decision was based on the assumption that the competency standards for juvenile court applied, which was a mistake. The court did not adequately support its determination with findings, and it appears to have applied an incorrect standard.The Supreme Court of Nevada vacated the certification order and the competency determination. The court held that a juvenile facing the possibility of prosecution as an adult on serious criminal charges must meet the adult criminal court standard for competence. The court remanded the case for the juvenile court to reassess D.C. Jr.'s competency using the correct standard. The court emphasized that the stakes were high, and the record did not show that the juvenile court correctly assessed D.C. Jr.'s competency to proceed. The court also vacated the order certifying D.C. Jr. for criminal proceedings as an adult, which followed the competency determination. View "In re D.C." on Justia Law

The case revolves around Timothy Williams, who was 16 years old when he committed the offense in question. Williams rang the doorbell of Everett and Leslie Lawson's home, pretending to have been injured in a car accident. When Leslie opened the door to help, Williams shot her twice, killing her instantly. Williams was charged in juvenile court for conduct that would constitute murder and felonious assault if committed by an adult. The state did not charge Williams in the juvenile-court complaint for conduct that would constitute tampering with evidence.The juvenile court found probable cause to believe that Williams committed all the offenses and transferred the case to the Hamilton County Court of Common Pleas. A grand jury then indicted Williams for murder, felonious assault, and tampering with evidence. Williams eventually pleaded guilty to involuntary manslaughter and tampering with evidence. He was sentenced to an aggregate 17-year prison term.Williams appealed his tampering-with-evidence conviction to the First District, arguing that his statutory and constitutional rights were violated when he was indicted for and convicted of tampering with evidence, because that charge had not been transferred from the juvenile court to the adult court. The First District, relying on a previous decision, held that the adult court had lacked subject-matter jurisdiction over the tampering-with-evidence charge because the juvenile court had not found probable cause on that charge. The appellate court thus vacated Williams’s tampering-with-evidence conviction.The state appealed to the Supreme Court of Ohio, which reaffirmed its previous holding that a defendant who was a juvenile when he committed an offense may be charged for and convicted of that offense in adult court even though a charge for the offense was not brought in juvenile court and considered in a bindover proceeding, if the charge is rooted in the same acts that were the subject of the juvenile complaint. Consequently, the Supreme Court of Ohio reversed the judgment of the First District Court of Appeals and remanded the matter to that court for it to resolve any remaining assignments of error. View "State v. Williams" on Justia Law

The case involves a nonmarital child who was removed from the mother's custody due to neglect. The Department of Children and Families filed a care and protection petition in the Juvenile Court. The father, who had established paternity but had not sought custody prior to the filing of the petition, was granted temporary custody. The mother later waived her right to a hearing and stipulated that she was unfit, leading to the Juvenile Court judge awarding "permanent" custody to the father. However, the child filed a motion to dismiss the care and protection case, arguing that the Juvenile Court's custody order was sufficient to award permanent custody to the father.The Juvenile Court judge denied the child's motion, citing the statutory scheme which addresses the rights and responsibilities of the parents of nonmarital children. This scheme provides that the mother of a nonmarital child "shall" have custody "[i]n the absence of an order or judgment of a [P]robate and [F]amily [C]ourt [judge] relative to custody." The current practice in the Juvenile Court is to require the parent, who has been awarded permanent custody of the child in connection with a care and protection action, to seek an order of custody from the Probate and Family Court under the nonmarital child statutory scheme.The Supreme Judicial Court of Massachusetts affirmed the Juvenile Court judge's order denying the child's motion to dismiss the care and protection case. The court agreed that the current practice best reflects the Legislature's intent and harmonizes the two statutory schemes. The court also concluded that the practice complies with due process. View "Care and Protection of Jaylen" on Justia Law

The case involves Manuel Dejesus Flores, who was convicted of four counts of lewd and lascivious acts committed against two victims under 14 years old. The victims, sisters B.C. and Y.G., lived with Flores in their family apartment between 2006 and 2008. Both victims testified that Flores had touched them inappropriately multiple times. B.C. disclosed the abuse to her friends in 2016, which was reported to Child Protective Services. The trial court admitted B.C.'s disclosure statements under the "fresh complaint" doctrine, despite the significant delay in reporting the abuse.The trial court also admitted expert testimony on Child Sexual Abuse Accommodation Syndrome (CSAAS), which explains common behaviors and reactions of child victims of sexual abuse. Flores was sentenced to a total of 50 years to life in prison and denied any conduct credits. Flores appealed the decision, arguing that the trial court erred in admitting B.C.'s disclosure statements and the CSAAS expert testimony.The Court of Appeal, Fourth Appellate District Division One State of California, affirmed the trial court's decision in part, reversed in part, and remanded with directions. The court found no error in the trial court's admission of victim disclosure evidence and CSAAS expert testimony. However, it agreed with Flores that he was entitled to presentence conduct credits, and remanded the matter for the trial court to calculate and award these credits. View "People v. Flores" on Justia Law

The case revolves around Taylor C., who was declared a ward of the court at the age of 14. After his wardship ended, Taylor successfully moved to dismiss his wardship petitions under the Welfare and Institutions Code section 782. He then sought to seal his juvenile court records. However, the juvenile court denied his request, citing his prior adjudications for committing forcible lewd conduct, which made his records ineligible for sealing under section 781, subdivision (a)(1)(F). Taylor appealed, arguing that the dismissal of his wardship petitions erased the adjudication of his offenses as if they never existed.The lower court had granted Taylor's motion to dismiss his wardship petitions, finding that the interests of justice and Taylor's welfare warranted dismissal and that he was no longer in need of rehabilitation. However, it denied his motion to seal his juvenile court records, citing the prohibition in subdivision (a)(1)(F) of section 781 on sealing records relating to his forcible lewd conduct offenses.The Court of Appeal of the State of California First Appellate District Division Three affirmed the lower court's decision. The court held that the dismissal of a juvenile petition under section 782 does not obviate the prohibition on sealing records under section 781, subdivision (a)(1)(F) in cases involving certain delineated offenses. The court found that Taylor's records were ineligible for sealing because section 782, subdivision (e) provides that dismissal of a petition does not alone constitute a sealing of records and section 781, subdivision (a)(1)(F), precludes sealing due to the forcible lewd conduct offenses. View "In re Taylor C." on Justia Law

The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.B., in a specific facility, St. Mary’s Home for Children, as ordered by the court. N.B., who has behavioral issues and Type I juvenile diabetes, was initially placed in Hasbro Children’s Hospital after her mother refused to take her home due to safety concerns. The Family Court ordered DCYF to place N.B. at St. Mary’s, but the facility refused to admit her due to her medical needs and behavioral issues. Despite DCYF's efforts to secure a placement for N.B., including contacting multiple potential placements and attempting to hire nurses to monitor N.B.'s diabetic care needs, no suitable placement was available.The Family Court found DCYF in contempt for failing to place N.B. at St. Mary’s, rejecting DCYF's argument that it was impossible to comply with the placement order. The court ordered DCYF to pay a daily sanction until it complied with the order. DCYF appealed the contempt order, arguing that the Family Court abused its discretion by finding that DCYF had not exercised reasonable efforts to place N.B. and that it was impossible to comply with the placement order.The Supreme Court of Rhode Island vacated the Family Court’s contempt order. The Supreme Court found that DCYF had made substantial efforts to place N.B. at St. Mary’s and other appropriate facilities, but compliance with the placement order was outside the department’s control due to circumstances such as the refusal of facilities to accept N.B. and ongoing nursing shortages related to the COVID-19 pandemic. The Supreme Court concluded that the Family Court had abused its discretion in finding that DCYF had not used reasonable efforts to place N.B. and in holding DCYF in contempt. View "In re N.B." on Justia Law

In 2022, a delinquency petition was filed against G.W., a 17-year-old, alleging that he had committed acts that would be considered theft and criminal trespass if committed as an adult. G.W. admitted to one allegation of theft and one allegation of criminal trespass. After G.W. went missing and was later found in Mississippi, he was returned to Indiana for his dispositional hearing. The juvenile court rejected G.W.'s request for home detention and ordered wardship of G.W. to the Department of Correction (DOC). However, the court's dispositional order did not include specific findings to support G.W.'s commitment, as required by statute.The Court of Appeals affirmed the juvenile court's decision but acknowledged that the order failed to comply with the applicable statutory requirements. The panel remanded the case for an amended dispositional order which includes the written findings and conclusions required by the statute. After the Court of Appeals had delivered its decision, but before it had certified that decision, the juvenile court issued an amended dispositional order which included the required statutory findings.The Indiana Supreme Court held that when a juvenile court fails to enter the requisite findings of fact in its dispositional order, an appellate court should neither affirm nor reverse. Instead, the proper remedy is to remand the case under Indiana Appellate Rule 66(C)(8) while holding the appeal in abeyance. This process adheres to the applicable statutory requirements, preserves the distinct roles played by trial courts and appellate courts, and (in some cases) justifies the cost of juvenile detention. The court remanded the case to the juvenile court for entry of its amended dispositional order. View "G.W. v. State" on Justia Law

The defendant, Darion Thomas, was arrested at a hospital in Iowa while accompanying his sick child and the child's mother, Tyliyah Parrow. During the arrest, law enforcement found a gun on Thomas and a backpack containing drugs. The backpack was searched after Parrow gave her consent. Thomas's cell phone, which was in Parrow's possession, was also seized and searched after a warrant was obtained five days later. Thomas was charged with possession with intent to distribute a controlled substance and possession of a firearm in furtherance of a drug trafficking crime. He pleaded guilty but reserved his right to appeal the denial of his motion to suppress evidence obtained from the backpack and cell phone.The district court denied Thomas's motion to suppress the evidence, ruling that Parrow had the authority to consent to the search of the backpack and that her consent was voluntary. The court also found that the five-day delay in obtaining a search warrant for the cell phone was reasonable. At sentencing, the court applied a two-level enhancement based on text messages that showed Thomas had supervised a minor in drug transactions.On appeal to the United States Court of Appeals for the Eighth Circuit, Thomas argued that the district court erred in its rulings on the search of the backpack, the delay in obtaining the search warrant for the cell phone, and the application of the two-level enhancement. The appellate court affirmed the district court's decisions, finding no clear error in its factual findings or legal conclusions. The court held that Parrow's consent to the search of the backpack was voluntary, the delay in obtaining the search warrant for the cell phone was reasonable, and the application of the two-level enhancement was justified based on the evidence presented. View "United States v. Thomas" on Justia Law

In 2016, 21-year-old Kwame De-Markquise Morrison initiated a sexual relationship with a 12-year-old girl, A.M. In 2017, A.M. became pregnant and gave birth to a child, who was later adopted. Morrison was charged with six counts of sexual assault upon a minor under 14 years of age and one count of use of a minor under the age of 14 in producing pornography. Morrison admitted to having sex with A.M. but claimed he believed she was 16 years old.The district court convicted Morrison of three counts of sexual assault upon a minor under 14 years of age and one count of use of a minor under the age of 14 in producing pornography. The court instructed the jury that a lack of knowledge or a mistake as to the victim's age is not a defense to a charge of using a minor in producing pornography. Morrison appealed, arguing that the instruction was inaccurate because the State is required to prove that the defendant "knowingly" used "a minor" in producing pornography.The Court of Appeals of Nevada agreed that the instruction was inaccurate. However, it found that the error was harmless beyond a reasonable doubt because Morrison admitted that he believed A.M. was 16 years old—and therefore a minor—during their sexual relationship. The court also rejected Morrison's other claims on appeal, including that the district court abused its discretion by denying his motion to dismiss counsel and that the State committed prosecutorial misconduct. Therefore, the court affirmed Morrison's judgment of conviction. View "Morrison v. State" on Justia Law

A mother appealed from juvenile court orders denying her petition for modification under Welfare and Institutions Code section 388 and terminating her parental rights under Welfare and Institutions Code section 366.26. The mother argued that the proceedings violated her substantive due process rights because the juvenile court was not required to consider her potential for further brain development, or her capacity to change, given her status as a teenager.The Court of Appeal of the State of California Second Appellate District Division Three affirmed the juvenile court orders. The court rejected the mother's arguments, concluding that sections 366.26 and 388 did not violate her due process rights. The court found that the focus of the proceedings shifted to permanence and stability for the child once reunification efforts failed. This shift did not violate the mother’s rights, even though she was a teenage parent. The court reasoned that the mother’s youth did not change or lessen the child’s need for permanence and stability.The court also dismissed the mother's reliance on cases concerning juvenile offenders in the criminal context, stating that the objectives and interests of the criminal justice system are vastly different from those of the juvenile dependency system. The court noted that the legislative choices to shift focus from reunification to permanency, require a parent to demonstrate changed circumstances, and prefer adoption as a permanent plan, were not intended to punish the parent, but to focus on the child's rights in proceedings where expediency is critical to the protection of their interests. View "In re S.G." on Justia Law