Justia U.S. Supreme Court Opinion SummariesArticles Posted in Juvenile Law
Virginia v. LeBlanc
In 1999, LeBlanc, then age 16, raped a 62- year-old woman. In 2003, a state trial court sentenced him to life in prison. Virginia had abolished traditional “parole” for felony offenders and enacted its “geriatric release” program, which allows older inmates to receive conditional release under some circumstances. In 2010, the Supreme Court held, in Graham v. Florida, that the Eighth Amendment prohibits juvenile offenders convicted of nonhomicide offenses from being sentenced to life without parole and that states must give defendants “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” LeBlanc sought to vacate his sentence in light of Graham. The state court denied the motion, citing the Supreme Court of Virginia’s decision in Angel v. Commonwealth, that Virginia’s geriatric release program satisfies Graham’s requirement of parole for juvenile offenders: “The regulations for conditional release under this statute provide that if the prisoner meets the qualifications for consideration contained in the statute, the factors used in the normal parole consideration process apply to conditional release decisions under this statute.” LeBlanc filed a federal habeas petition, 28 U.S.C. 2254. The Supreme Court reversed the Fourth Circuit’s grant of relief. The Virginia trial court’s ruling, resting on the Virginia Supreme Court’s ruling in Angel, was not objectively unreasonable in light of existing Supreme Court authority. View "Virginia v. LeBlanc" on Justia Law
Montgomery v. Louisiana
Montgomery was 17 years old in 1963, when he killed a deputy in Louisiana. The jury returned a verdict of “guilty without capital punishment,” which carried an automatic sentence of life without parole. Nearly 50 years later, the Supreme Court decided, in Miller v. Alabama, that mandatory life without parole for juvenile offenders violates the Eighth Amendment’s prohibition on cruel and unusual punishments. The trial court denied his motion for relief. His application for a supervisory writ was denied by the Louisiana Supreme Court, which had previously held that Miller does not have retroactive effect in state collateral review. The Supreme Court reversed. Courts must give retroactive effect to new watershed procedural rules and to substantive rules of constitutional law. Substantive constitutional rules include “rules forbidding criminal punishment of certain primary conduct” and “rules prohibiting a certain category of punishment for a class of defendants because of their status or offense.” Miller announced a substantive rule of constitutional law, which is retroactive because it necessarily carries a significant risk that a defendant faces a punishment that the law cannot impose. A state may remedy a Miller violation by extending parole eligibility to juvenile offenders. This would neither impose an onerous burden nor disturb the finality of state convictions and would afford someone like Montgomery, who may have evolved from a troubled, misguided youth to a model member of the prison community, the opportunity to demonstrate the truth of Miller’s central intuition—that children who commit even heinous crimes are capable of change. View "Montgomery v. Louisiana" on Justia Law
Adoptive Couple v. Baby Girl
The Indian Child Welfare Act of 1978 (ICWA) establishes federal standards for state-court custody proceedings involving Indian children. It bars involuntary termination of parental rights absent a heightened showing that serious harm to the Indian child is likely to result from the parent’s “continued custody” of the child, 25 U.S.C. 1912(f); conditions involuntary termination of parental rights on showing that remedial efforts have been made to prevent the “breakup of the Indian family,” (1912(d)); and provides preferences for adoption of Indian children to extended family, members of the tribe, and other Indian families, (1915(a)). Before Baby Girl’s birth, Biological Father, a member of the Cherokee Nation, agreed to relinquish his parental rights. Birth Mother put Baby Girl up for adoption through a private agency and selected non-Indian adoptive parents. During the pregnancy and the first four months of Baby Girl’s life, Biological Father provided no financial assistance. Four months after the birth, Adoptive Couple served Biological Father with notice of the pending adoption. Biological Father sought custody and stated that he did not consent to the adoption. South Carolina Family Court denied the adoption petition and awarded Biological Father custody. At the age of 27 months, Baby Girl was given to Biological Father, whom she had never met. The South Carolina Supreme Court affirmed. The U.S. Supreme Court reversed, stating that, assuming that Biological Father is a “parent” under the ICWA, that law does not bar termination of his parental rights. “Continued custody” refers to custody that a parent already has or at least has had; section 1912(f) does not apply where the Indian parent never had custody. Section 1912(d) conditions involuntary termination of parental rights on a showing of efforts to prevent the breakup of the Indian family; the section applies only when the “breakup” would be precipitated by terminating parental rights. When an Indian parent abandons an Indian child before birth and that child has never been in that parent’s custody, the “breakup of the Indian family” has long since occurred, and section 1912(d) is inapplicable. Section 1915(a)’s placement preferences are inapplicable if no alternative party has formally sought to adopt the child. Biological Father did not seek to adopt, but only argued that his parental rights should not be terminated. View "Adoptive Couple v. Baby Girl" on Justia Law
Miller v. Alabama
In each of two underlying cases, a 14-year-old was convicted of murder and sentenced to a mandatory term of life imprisonment without possibility of parole. The highest courts of Alabama and Arkansas upheld the sentences. The Supreme Court reversed. The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. Children are constitutionally different from adults for sentencing purposes. Their lack of maturity and underdeveloped sense of responsibility lead to recklessness, impulsiveness, and heedless risk-taking. They are more vulnerable to negative influences and lack ability to extricate themselves from horrific, crime-producing settings. A child’s actions are less likely to be evidence of irretrievable depravity. The mandatory penalty schemes at issue prevent the sentencing court from considering youth and from assessing whether the harshest term of imprisonment proportionately punishes a juvenile offender. Life-without-parole sentences share characteristics with death sentences, demanding individualized sentencing. The Court rejected the states’ argument that courts and prosecutors sufficiently consider a juvenile defendant’s age, background and the circumstances of his crime, when deciding whether to try him as an adult. The argument ignores that many states use mandatory transfer systems or lodge the decision in the hands of the prosecutors, rather than courts. View "Miller v. Alabama" on Justia Law
United States v. Juvenile Male
In 2005, respondent was charged with delinquency under the Federal Juvenile Delinquency Act, 18 U.S.C. 5031 et seq., for sexually abusing a boy for approximately two years until respondent was 15 years old and his victim was 12 years old. Respondent was sentenced to two years of juvenile detention followed by juvenile supervision until his 21st birthday. In 2006, while respondent remained in juvenile detention, Congress enacted the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16902 et seq. In July 2007, the District Court determined that respondent had failed to comply with the requirements of his prerelease program. On appeal, respondent challenged his "special conditio[n]" of supervision and requested that the Court of Appeals "reverse th[e] portion of his sentence requiring Sex Offender Registration and remand with instructions that the district court ... strik[e] Sex Offender Registration as a condition of juvenile supervision." Over a year after respondent's 21st birthday, the Court of Appeals handed down its decision and held that the SORNA requirements violated the Ex Post Facto Clause of the Constitution, Art. I, section 9, cl. 3, when applied to juveniles adjudicated as delinquent before SORNA's enactment. The Court held that the Court of Appeals had no authority to enter that judgment because it had no live controversy before it where respondent had turned 21 and where the capable-of-repetition exception to mootness did not apply in this case. Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded with instructions to dismiss the appeal. View "United States v. Juvenile Male" on Justia Law
Brown, et al. v. Entertainment Merchants Assn. et al.
Respondents, representing the video game and software industries, filed a preenforcement challenge to California Assembly Bill 1179 (Act), Cal. Civ. Code Ann. 1746-1746.5, which restricted the sale or rental of violent video games to minors. At issue was whether the Act comported with the First Amendment. The Court held that, because the Act imposed a restriction on the content of protected speech, it was invalid unless California could demonstrate that it passed strict scrutiny. The Court held that California had a legitimate interest in addressing a serious social problem and helping concerned parents control their children. The Court held, however, that as a means of protecting children from portrayals of violence, the legislation was seriously underinclusive, not only because it excluded portrayals other than video games, but also because it permitted a parental or avuncular veto. The Court also held that, as a means of assisting concerned parents, it was seriously overinclusive because it abridged the First Amendment rights of young people whose parents think violent video games were a harmless pastime. The Court further held that the overbreadth in achieving one goal was not cured by the overbreadth in achieving the other and therefore, the legislation could not survive strict scrutiny. Accordingly, the court affirmed the judgment of the Ninth Circuit enjoining the Act's enforcement. View "Brown, et al. v. Entertainment Merchants Assn. et al." on Justia Law
J. D. B. v. North Carolina
J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time. View "J. D. B. v. North Carolina" on Justia Law
Camreta v. Greene, et al.; Alford v. Greene, et al.
Nearly a decade ago, petitioners, a state child protective services worker and a county deputy sheriff, interviewed then 9-year-old S.G. at her Oregon elementary school about allegations that her father had sexually abused her. Her father stood trial for that abuse but the jury failed to reach a verdict and the charges were later dismissed. S.G.'s mother subsequently sued petitioners on S.G.'s behalf for damages under 42 U.S.C. 1983, alleging that the in-school interview breached the Fourth Amendment's proscription on unreasonable seizures. The Ninth Circuit held that petitioners' conduct violated the Fourth Amendment but that they were entitled to qualified immunity from damages liability because no clearly established law had warned them of the illegality of the conduct. Although judgment was entered in petitioners' favor, they petitioned the Court to review the Ninth Circuit's ruling that their conduct violated the Fourth Amendment. At issue was whether government officials who prevailed on grounds of qualified immunity could obtain the Court's review of a court of appeals' decision that their conduct violated the Constitution. Also at issue was, if the Court could consider cases in this procedural posture, did the Ninth Circuit correctly determine that this interview breached the Fourth Amendment. The Court held that it could generally review a lower court's constitutional ruling at the behest of a government official granted immunity but could not do so in this case for reasons peculiar to it. The case had become moot because the child had grown up and moved across the country and so would never again be subject to the Oregon in-school interviewing practices whose constitutionality was at issue. Therefore, the Court did not reach the Fourth Amendment question in this case and vacated the part of the Ninth Circuit's opinion that decided the Fourth Amendment issue.