Justia Civil Rights Opinion Summaries

In 1990, defendant, then 14 years old, was arrested for two fatal shootings. Following a discretionary hearing under the Juvenile Court Act, the court allowed defendant to be prosecuted under the criminal laws. He was convicted of two first degree murders, attempted first degree murders of two others, and home invasion. Because defendant was convicted of murdering more than one victim, the Unified Code of Corrections, 730 ILCS 5/5-8-1(a)(1)(c), required a term of natural life imprisonment, with parole not available. He was also sentenced to 30 years for each attempted murder and home invasion, all to run concurrently. The appellate court affirmed. In 1996-1998 defendant filed three post-conviction petitions. All were dismissed; the appellate court affirmed the dismissals. In 2002, defendant filed another petition, arguing that the natural life sentence was unconstitutional because defendant did not actually participate in the act of killing; that the sentence violated the Eighth Amendment; and that the statute requiring a mandatory life sentence violated the Illinois Constitution as applied to a 14-year-old. The circuit court dismissed, noting that defendant carried a weapon and actually entered the abode where the murders occurred. The appellate court affirmed. Defendant another petition in 2011, arguing violation of the Eighth Amendment in light of the Supreme Court’s 2010 decision, Graham v. Florida, and ineffective assistance because counsel failed to interview an eyewitness before the juvenile hearing. The court denied the petition. While appeal was pending, the Supreme Court decided in Miller v. Alabama (2012), that “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments.’ ” The appellate court concluded that Miller applies retroactively on post-conviction review and remanded for a new sentencing hearing, but upheld denial of the ineffective assistance claim. The Illinois Supreme Court affirmed. View "People v. Davis" on Justia Law

Appellant was charged with several offenses stemming from two separate shootings. Appellant was age seventeen when the offenses were committed. After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to consecutive terms of life imprisonment without parole. On appeal, Appellant contended that his sentence amounted to cruel and unusual punishment. The court of appeals affirmed, holding (1) Appellant’s sentence was proper under Miller v. Alabama because the sentence imposed in this case was not mandatory but, rather, an exercise of the trial court’s discretion; and (2) the trial court did not violate the Eighth Amendment by failing to consider Appellant’s youth as a mitigating factor in sentencing Appellant. The Supreme Court reversed, holding (1) the Eighth Amendment requires trial courts to consider youth as a mitigating factor when sentencing a child to life without parole for homicide, and the record must reflect that the court specifically considered the juvenile offender’s youth as a mitigating factor at sentencing when a prison term of life without parole is imposed; and (2) because Appellant might not have been given the benefit of the consideration of youth as a mitigating factor, his sentence did not comport with the procedural strictures of Miller. View "State v. Long" on Justia Law

I.T., who admitted to conduct that would be a Class B felony child molesting if committed by an adult, was ordered by the trial court to undergo therapeutic polygraph examinations. During one of those exams, I.T. admitted to molesting two other children. Based on those statements, the State filed a new delinquency petition. I.T. moved to dismiss the petition, arguing that the Juvenile Mental Health Statute, which bars a child’s statement to a mental health evaluator from being admitted into evidence to prove delinquency, barred the State’s evidence. The trial court granted the motion. The State appealed. The Supreme Court affirmed, holding (1) the State may appeal a juvenile court order that suppresses evidence if doing so terminates the proceeding; and (2) the Statute’s limited immunity prohibits both use and derivative use of a juvenile’s statements to prove delinquency. View "State v. I.T." on Justia Law

Defendant was convicted of first degree murder and sentenced to life imprisonment for a murder he committed when he was sixteen years old. More than fifteen years later, Defendant filed an amended postconviction motion challenging his life imprisonment sentence. The district court denied the motion. After Defendant appealed, the U.S. Supreme Court decided Miller v. Alabama, which held that the Eighth Amendment forbids a state sentencing scheme that mandates life in prison without the possibility of parole for a juvenile offender convicted of homicide. The Supreme Court reversed in this case, holding (1) the rule announced in Miller applied retroactively to Defendant; and (2) Defendant’s sentence was unconstitutional under Miller, and therefore, Defendant was entitled to be resentenced. Remanded. View "State v. Mantich" on Justia Law

Responding to a report of underage drinking in a home, officers found a group celebrating eighth grade graduation. Police asked the teens to step outside individually for breathalyzer testing. Seven tested positive for alcohol. Police arrested them and notified their parents. In the morning, a juvenile worker arrived at the police station, and, after speaking with a judge, indicated that the children were to be detained for a court appearance the next day. At the regional juvenile detention center, the minors underwent routine fingerprinting, mug shots, and metal-detection screening. During a hygiene inspection and health screening, they were required to disrobe completely for visual inspection to detect “injuries, physical abnormalities, scars and body markings, ectoparasites, and general physical condition.” A same-sex youth worker observed the juveniles for several minutes from a distance of one to two feet, recording findings for review by an R.N. The minors were required to shower with delousing shampoo. They were released the following day. The charges were dropped. In a suit under 42 U.S.C. 1983, the district court granted partial summary judgment in favor of the juveniles, based on a “clearly established right for both adults and juveniles to be free from strip searches absent individualized suspicion” that negated a qualified immunity defense. The Sixth Circuit reversed, stating that no clearly established principle of constitutional law forbids a juvenile detention center from implementing a generally applicable, suspicionless strip-search policy upon intake into the facility.View "T. S. v. Doe" on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

Plaintiff-Appellee Brandon Blackmon brought a 42 U.S.C. 1982 action against various members of the juvenile detention center in Sedgwick, Kansas, alleging they violated his Fourteenth Amendment rights as a pre-trial detainee when he was taken there as an eleven-year-old. He claimed that the staff regularly used a "Pro-Straint Restraining Chair, Violent Prisoner Model" sometimes as a legitimate effort to stop him from committing suicide, but mostly, as plaintiff contended, to punish him. The chair is equipped with wrist, chest and ankle restraints; as a juvenile detainee, plaintiff was 4'11' and 96 pounds. The district court denied defendants' motion for dismissal based on qualified immunity grounds. Defendants appealed to the Tenth Circuit, maintaining that the district court erred in holding that the facts, when viewed in a light favorable to plaintiff, suggested that defendants sometimes exceeded the scope of qualified immunity. After its review of the district court record, the Tenth Circuit affirmed in all respects except one: the Court directed the district court to grant qualified immunity to defendant Sutton on plaintiff's "failure to transfer" claim. View "Blackmon v. Sutton, et al" on Justia Law

Petitioner was a juvenile charged as an adult with attempted first-degree murder with a deadly weapon. After the U.S. Supreme Court issued its decision in Graham v. Florida, Petitioner filed a motion to have a bond set. The trial court denied the motion. Petitioner filed a second petition for writ of habeas corpus, arguing (1) the Florida Constitution provides for pretrial release as a matter of right for a noncapital offense or an offense that does not carry the possibility of a life sentence, and (2) because Graham prohibits the State from sentencing him to life without an opportunity for parole, he was entitled to bond under the provisions of the State Constitution. The court of appeal denied the petition, concluding that Graham does not impact a juvenile defendant's entitlement to bond because the Florida Constitution considers only the classification of the offense, not a defendant's eventual sentence. The Supreme Court quashed the decision below, holding that juvenile offenders such as Petitioner were entitled to bond under the Florida Constitution because they cannot be charged with a crime punishable by life imprisonment under Florida's current statutory scheme and Graham. View "Treacy v. Lamberti" on Justia Law

In 2010 the Supreme Court held, in Miller v. Alabama, that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment prohibition on cruel and unusual punishments. Three individuals, each serving a mandatory sentence of life without the possibility of parole for offenses committed as juveniles, sought authorization to file successive habeas corpus petitions under 28 U.S.C. 2254 and 2255 to raise Miller claims. The parties agreed that Miller states a new rule of constitutional law, but Pennsylvania (the state in which two petitioners were convicted) argued that Miller was not retroactive; the federal prosecutor claimed that Miller was retroactive but that the other petitioner’s sentence satisfied the new Miller rule. The Third Circuit found that the petitioners had made a prima facie showing that Miller is retroactive and authorized successive habeas petitions. View "In re: Grant" on Justia Law

Following the denial of her motion for new trial, Chanell Pitts appealed her convictions and misdemeanor sentences for 2011 violations of OCGA 20-2-690.1(the "mandatory education statute"). Her sole challenge was to the constitutionality of the statute. Finding no error in the trial court’s denial, the Supreme Court affirmed. View "Pitts v. Georgia" on Justia Law