Justia Civil Rights Opinion Summaries

The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue.

Ariz. Rev. Stat 8-238 requires juveniles charged with certain offenses and summoned to appear at an advisory hearing to submit to the investigating law enforcement agency a sample of buccal cells or other bodily substances for DNA testing and extraction. The penalty for failure to comply is revocation of release pending adjudication. In this case seven juveniles were separately charged with violations of offenses specified in section 8-238(A). Each was summoned to an advisory hearing, released, and ordered to submit a buccal sample to law enforcement within five days. In each case, the superior court rejected Fourth Amendment objections to the sampling order. The Juveniles jointly filed a special action in the court of appeals, which held that requiring the submission of DNA samples from juveniles for whom a probable cause determination has been made does not violate the Fourth Amendment. The Supreme Court vacated the opinion of the court of appeals, holding that the statutory scheme violated the Fourth Amendment prohibition against unreasonable searches and seizures.

This matter involved two cases, one involving two youths who appeared in youth court for detention hearings and one involving an adult who pled guilty to driving under the influence in justice court. After appearing in district court, the youths filed motions to substitute district court judge, and the court denied the motions as untimely. After the adult pled guilty in justice court, she appealed only the justice court's denial of her pretrial suppression motion, which the district court denied as untimely. The Supreme Court granted a petition for writ of supervisory control for the youths and denied it for the adult, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court correctly denied the adult's motion for substitution of district court judge, as no right exists under Mont. Code Ann. 3-1-804 to substitute a district judge in an appeal of a specific pre-trial legal ruling from justice court.

Appellant N.D. was a juvenile when he was adjudicated delinquent for commission of aggravated robbery and possession of a weapon. After N.D. escaped from the detention center, the State filed a felony information charging N.D. as an adult with capital murder, escape in the first degree, aggravated robbery, theft of property, and second-degree battery. After the Supreme Court reversed the criminal court's denial of N.D.'s motion to transfer his case to the juvenile court, the criminal court transferred N.D.'s case to juvenile court. The juvenile court subsequently entered a decision that N.D. be designated for extended juvenile jurisdiction (EJJ). N.D. appealed, asserting that the criminal court already declined to make such a designation, and because the Supreme Court did not reverse that refusal in N.D.'s first appeal, the issue was decided by law of the case. The Supreme Court affirmed, holding that the Court did not previously reach a decision or provide direction to the criminal court with respect to EJJ designation, nor did the criminal court make a decision regarding EJJ designation, and so the law-of-the case doctrine did not bar the juvenile court from granting the State's motion for an EJJ designation.

Sixteen-year-old C.B. was charged with the felony offenses of, inter alia, capital murder, aggravated robbery, first-degree escape, and theft of property. C.B. filed a motion to dismiss and to declare Ark. Code Ann. 9-27-318 unconstitutional and a motion to transfer to juvenile court. In challenging the constitutionality of section 9-27-318, C.B. contended that the statute, among other things, violated the separation of powers doctrine by improperly vesting in the local prosecuting attorney power to determine which court has initial jurisdiction over certain classes of juveniles. The circuit court denied both motions. The Supreme Court affirmed, holding (1) section 9-27-318 was constitutional; and (2) the circuit court did not clearly err in denying C.B.'s motion to transfer.

At issue in these two consolidated appeals was whether the district court properly calculated the time period in which to file a motion for substitution of district judge in youth court and on an appeal from justice court. Petitioners, two youths who appeared in court or detention hearings and a defendant who pled guilty in justice court to driving under the influence, petitioned for writ of supervisory control, claiming that the district court incorrectly denied as untimely their motions for substitution of district court judge in those cases. The Supreme Court reversed in part and affirmed in part, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court properly calculated the time period in which to file a motion for substitution of district court on the appeal from justice court.

C.P. was fifteen years old when he was charged with two counts of rape and one count of kidnapping with sexual motivation. The juvenile court found C.P. to be a delinquent child and designated him a serious youthful offender in relation to each offense. Further, the court classified C.P. a public-registry-qualified juvenile-offender registrant (PRQJOR) and a Tier III sex-offender/child-victim offender pursuant to Ohio Rev. Code 2152.86. At issue on appeal was the constitutionality of section 2152.86, which created the new class of juvenile sex-offender registrants, PRQJORs, who are automatically subject to mandatory, lifetime sex-offender registration and notification requirements without the participation of a juvenile judge. The Supreme Court reversed, holding that to the extent that it imposes such requirements on juvenile offenders tried with the juvenile system, section 2152.86 violates the constitutional prohibition against cruel and unusual punishment and the due process clauses of the state and federal Constitutions.

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings.

A disabled child, born in 1996, was a student in the Sutton public school system from 1999 until 2005, when his parent were dissatisfied with the individualized education program developed under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1491, and the services he was receiving. They removed him from the school and enrolled him in a private learning center. The Massachusetts Bureau of Special Education Appeals determined that the 2005 IEP complied with the IDEA. The district court upheld the decision on summary judgment. The First Circuit affirmed, rejecting an argument that the court could not determine compliance without first determining the child's potential for learning and self-sufficiency. The district court properly concluded that the child's potential was unknowable and that the IEP was reasonably calculated to confer educational benefits. The parents did not raise triable claims under the First Amendment, the Rehabilitation Act of 1973, Titles II and V of the Americans with Disabilities Act, or 42 U.S.C. 1983 and 1985; plaintiffs “cannot disguise an IDEA claim in other garb.”

When he was fifteen years old, E.C. pled guilty to breaking and entering and rape. After E.C. was released from custody and placed under parole supervision, a team of attorneys filed a petition for a writ of habeas corpus on E.C.'s behalf alleging that E.C.'s guilty plea was neither knowing nor voluntary and was unconstitutionally invalid because of ineffective assistance of counsel. Six days after his petition was filed, E.C. was released from parole supervision. The circuit court dismissed the petition, concluding that it had no jurisdiction to consider the petition and that the habeas corpus proceeding was moot. The Supreme Court reversed, holding (1) the circuit court had active jurisdiction over the proceeding because E.C. was detained for purposes of habeas corpus when the petition was filed; and (2) E.C.'s release from probation during the pendency of the habeas corpus proceeding did not automatically render the proceeding moot, as the collateral consequences imposed on E.C. by the convictions he challenged were sufficient to sustain a continued controversy.