Justia Civil Rights Opinion Summaries

After two commitment hearings, the juvenile court entered an order committing Alan L. to the Office of Juvenile Services (OJS) for commitment at a youth rehabilitation and treatment center. In its first order, the court concluded that the State had not proved the necessary conditions for commitment, but the court subsequently found that the evidence supported a commitment order. Alan appealed, arguing (1) claim preclusion barred the State from presenting any new evidence at the second commitment hearing that was available to it before the first commitment hearing; and (2) the commitment hearing violated his right to due process because he could not confront and cross-examine individuals who provided adverse information against him. The Supreme Court affirmed, holding (1) Alan was not deprived of his right to procedural due process despite the State’s failure to comply with case law for seeking a new disposition or commitment to OJS; and (2) new evidence at the second commitment hearing, which became available after the first hearing, showed a change of circumstances warranting Alan’s commitment to OJS, and claim preclusion does not bar consideration of changed circumstances. View "In re Interest of Alan L." on Justia Law

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law

A complaint was filed in juvenile court alleging that A.G. was delinquent for engaging in conduct that, if committed by an adult, would have constituted aggravated robbery and kidnapping, with firearms specifications as to each. A.G. admitted to the allegations in the complaint. The juvenile court found the allegations proved beyond a reasonable doubt and ordered that A.G. be committed to the Department of Youth Services for minimum terms of one year for each of the aggravated robbery and kidnapping adjudications. A.G. appealed, arguing that the juvenile court erred in failing to merge his adjudications for aggravated robbery and kidnapping as “allied offenses of similar import” and that his trial counsel was ineffective for failing to raise the allied-offenses issue. The Court of Appeals denied relief, concluding that the aggravated robbery and kidnapping would constituted allied offenses of similar import under Ohio Rev. Code 2941.25 if committed by an adult but that criminal statutes do not apply in juvenile delinquency proceedings. The Supreme Court reversed, holding that juvenile courts must conduct the same double-jeopardy analysis in delinquency proceedings that other courts apply in adult criminal proceedings to protect a child’s right against double jeopardy. View "In re A.G." on Justia Law

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

In 2010, 15-year-old Turner fired a gun at a group of young men, killing Allen, and grazing two others. Turner knew the victims from high school. A jury convicted Turner of second degree murder (Pen. Code, 187(a)), and two counts of attempted murder, and found true the allegations that Turner, personally used a firearm and personally inflicted great bodily injury. The court sentenced Turner to an aggregate state prison term of 84 years-to-life. The court of appeal affirmed the convictions, but modified the sentence, so that Turner will be entitled to a parole hearing after 25 years. The court upheld the trial court’s refusal to instruct the jury on the theories imperfect self-defense and justifiable homicide based on self-defense; its use of the instructions on a kill zone theory. The court also rejected a claim of ineffective assistance of counsel based on trial counsel’s failure to raise the issue of cruel and unusual punishment below and failure to present readily available mitigating evidence in support of a lesser sentence. View "People v. Turner" on Justia Law

The juvenile court adjudicated Appellant, a juvenile, delinquent on sex offenses. At disposition, the juvenile court did not record a finding regarding Appellant’s age at the time the offenses were committed. Upon Appellant’s release from the Ohio Department of Youth Services, the court scheduled a sex-offender-classification hearing. Appellant opposed his classification as a juvenile-sex-offender registrant, arguing that he was ineligible for classification because he was under the age of fourteen when the offenses were committed and because classification would violate the constitutional prohibition against double jeopardy. After a hearing, the juvenile court found (1) Appellant had committed at least one offense when he was fourteen years of age, and (2) Appellant should be designated a juvenile offender registrant and classified as a Tier II offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a determination of a juvenile sex offender’s age at the time of the offense can be made at any time prior to or during the classification hearing; and (2) the imposition of classification upon release from a secure facility and for a time period beyond the juvenile offender’s attainment of age eighteen or twenty-one does not violate the offender’s due process rights or the constitutional prohibition against double jeopardy. View "In re D.S." on Justia Law

Defendant was charged with first degree assault and an associated armed criminal action count under Mo. Rev. Stat. 571.015.1. Defendant, who was a juvenile at the time of the offenses, moved to dismiss the armed criminal action charge on the ground that the application of the sentencing provisions of section 571.015.1 to juvenile offenders is unconstitutional. The trial court agreed with Defendant, concluding that section 571.015.1 is unconstitutional as applied to all juvenile offenders and declared unconstitutional the three-year mandatory minimum incarceration requirement for juveniles who are certified to stand trial as adults. The State subsequently filed this interlocutory appeal challenging the trial court’s determination regarding the constitutional validity of section 571.015.1. The Supreme Court dismissed the State’s appeal, holding that the State has no right to appeal this interlocutory decision under section 547.200.1, nor does the trial court’s decision constitute a final judgment from which the State is entitled to appeal under section 547.200.2. View "State v. Smiley" on Justia Law

A family member reported to Michigan Children’s Protective Services (CPS) that Barber was neglecting J.B. Miller, a CPS social worker, interviewed J.B. at his public elementary school without a court order or Barber’s consent. Miller interviewed Barber, who defended his marijuana and prescription-drug use as medically authorized. Days later, Miller again interviewed J.B. at school without a court order or parental consent and spoke with J.B.’s paternal grandmother. Miller obtained a court order, placing J.B. in protective custody pending a hearing, Mich. Comp. Laws 722.638, and picked J.B. up from school. After a hearing, the judge found probable cause to support the petition, but returned J.B. to Barber’s custody conditioned on: Barber’s abstaining from marijuana, submitting to drug screening, and ensuring that J.B. has constant adult supervision. Barber sued Miller under 42 U.S.C. 1983 for violating his substantive due process rights by interviewing J.B. without a court order or parental consent; falsehoods in the petition; and removing J.B. from school, and challenged the statute as facially unconstitutional. The Sixth Circuit affirmed dismissal on grounds of absolute and qualified immunity and found that Barber lacked standing for his constitutional challenge to the statute. View "Barber v. Miller" on Justia Law

In 2005, Martinez, Vallejo, and 47 others were indicted for crimes committed while they were members of the Milwaukee chapter of the Latin Kings gang organization. Martinez and Vallejo pled guilty to a RICO offense, 18 U.S.C. 1962, and admitted to engaging in predicate racketeering activities, including a 2003 murder. Vallejo, who was 17 years old at the time, and Martinez, who was 16, each fired several shots at the victim. Martinez also pled guilty to attempted murder of a rival gang member; Vallejo’s plea agreement included two attempted murders. All of the attempted murders occurred while the defendants were under the age of 18. In both cases, the court imposed the “maximum sentence”—life in prison.. Neither Martinez nor Vallejo filed a direct appeal. In 2012, the Supreme Court held, in Miller v. Alabama, that the Eighth Amendment prohibits the imposition of a mandatory life sentence without the possibility of parole for juveniles. The Seventh Circuit affirmed the district court’s denial of their motion to vacate, set aside, or correct their sentences under 28 U.S.C. 2255. Martinez and Vallejo’s life sentences were imposed after an individualized sentencing, and not by statutory mandate,and did not violate Miller. View "Vallejo v. United States" on Justia Law

J.B., age 12, got into a fight and brandished a homemade knife over a neighborhood girl, stating that could kill her. A parent called the state police. J.B. admitted to threatening to break a girl’s arms and to holding the knife. J.B.’s father was told that charges of terroristic threats and summary harassment would be filed. Three weeks later, a juvenile allegation was filed. J.B. was transported to the Lancaster County Youth Intervention Center, processed, and subjected to a strip search pursuant to LYIC policy to look for signs of “injuries, markings, skin conditions, signs of abuse, or further contraband.” J.B. stood behind a curtain so that only the officer conducting the search could observe him, removed his pants and underwear for approximately 90 seconds, and was asked to bend over, spread his buttocks, and cough. J.B. was detained for three days. He ultimately entered into a consent decree with an opportunity to have his record expunged. In his suit under 42 U.S.C. 1983 for false arrest, unreasonable search and seizure, false imprisonment, and violations of due process, the Third Circuit concluded that defendants were entitled to partial summary judgment. The Supreme Court holding in Florence v. Board of Chosen Freeholders, that all arrestees committed to general population of a detention center may be subject to a close visual inspection while undressed, applies to juvenile offenders admitted to general population in a juvenile detention center. View "J. B. v. Fassnacht" on Justia Law