Juvenile Law Case Briefs PDF

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A break down of all cases required to know for the course...

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Juvenile Law Case Briefs In re Gault (1967) Facts Procedure Lower Courts: Issue Holding

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Mckeiver v. Pennsylvania (1971) Facts Issue Holding Reasoning

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E.J. v. State (2005) Facts Issue Holding Reasoning

6 6 7 7 7

State v. Menuto (2005) Facts

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Roper v. Simmons (2005) Facts Procedural Summary Issue Holding Reasoning Dissent

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Graham v. Florida (2010) Facts Procedural Summary Issue Holding Reasoning

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Miller v. Alabama (2012) Facts Procedural Summary Issue

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Holding Reasoning

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Horsley v. State (2015) Facts Procedural Summary Issue Holding

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Lightsey v. State (2015) Facts Issue Holding Reasoning

16 16 16 16 16

Landrum v. State (2016) Facts Issue Holding Reasoning

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In re Gault (1967) Facts ● ●

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On June , 1964, Jerry Gault, 15, was accused of making an obscene telephone call to a neighbor, Mrs. Cook After Mrs. Cook filed a complaint, Gault and a friend, Ronald Lewis, were arrested and taken to the Children’s Detention Home ○ Gault was on probation when arrested, for being in the company of another boy who had stolen a wallet from a woman’s purse At the time of the arrest, Gault’s parents were at work ○ Arresting officer left no notice for them and did not make an effort to inform them of their son’s arrest Gault’s mother could not find Gault and sent his brother to go look for him ○ They eventually learned of Gault’s arrest from the family of Ronald Lewis When Mrs. Gault arrived at the Detention Home, she was told that a hearing was scheduled in juvenile court the following day The arresting officer filed a petition with the court on the same day of Gault’s initial court hearing ○ Petition was not served on Gault or his parents ○ Petition was not seen until more than two months later (August 17, 1964) the day of Gault’s habeas corpus hearing The June 9 hearing was informal ○ Mrs. Cook was not present ○ No transcript or recording was made ○ No one was sworn in prior to testifying Gault was questioned by the judge and there are conflicting accounts as to what, if anything, Gault admitted After the hearing, Gault was taken back to the Detention Home ○ He was detained for another two or three days before being released When released, his parents were notified that another hearing was scheduled for June 15, 1964 Mrs. Cook was not present for the June 15th hearing, despite Mrs. Gault’s request that she be there “so she could see which boy had done the talking, the dirty talking over the phone” No record was made and there are conflicting accounts regarding any admissions by Gault At this hearing, the probation officers filed a report listing the charge as lewd phone calls ○ An adult charged with the same crime would receive a max sentence of $50 fine and two months in jail At the conclusion of the hearing, the judge committed Gault to juvenile detention for six

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years, until he turned 21 Gault’s parents filed a petition for a writ of habeas corpus, which was dismissed by both the Superior Court of Arizona and the Arizona Supreme Court ○ United States Supreme Court agreed to hear the case to determine the procedure due process rights of a juvenile criminal defendant

Procedure Lower Courts: ●

The proceeding against Gault were conducted by a judge of the Superior Court of Arizona who was designated by his colleagues to serve as a juvenile court judge

Ruling ● The juvenile court judge committed Gault to juvenile detention until was attained the age of 21 ● At this time, no appeal was permitted in juvenile cases by Arizona law ○ Therefore, a habeas petition was filed with the Supreme Court of Arizona

Issue ●

Is it constitutional to take a child’s liberty without following due process?

Holding ●

No. Both children and adults have a right to due process under the 14th Amendment

Supreme Court stated that the following due process procedures must be given to juveniles as well as adults: ● Notice of Charges ○ Both Gault and his parents should have received written notice of the charges against him. That notice should have been delivered far enough in advance to allow time to prepare a defense ● Right to Counsel ○ Gault and his parents should have been told that they had a right to a lawyer, and that one would be appointed to them if they could not afford one ● Right to Remain Silent ○ The Court said Gault did not have to testify against himself. His confession could not be used against him unless it was obtained properly ● Right to Confrontation ○ Without a valid confession, only testimony from witnesses who had been sworn in could be used against Geralf, and he had a constitutional right to confront the witnesses against him

Mckeiver v. Pennsylvania (1971) Facts ●

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Joseph McKeiver, 16, was adjudicated as a juvenile delinquent after being charged with robbery, larceny, and receiving stolen goods ○ He participated with 20 or 30 youths who pursued three young teenagers and took 25 cents from them ○ Felonies under Pennsylvania law Another boy, Terry, was charged with acts of juvenile delinquency including assault and battery and conspiracy ○ Hit a police officer with his fists and with a stick when the officer broke up a boys’ fight Terry and others were watching In each proceeding, counsel’s request for trial by jury was denied ○ Decisions were affirmed by the Pennsylvania Supreme Court In North Carolina, juveniles ranging from 11 to 15 years of age had been declared delinquent by the juvenile court after their requests for trial by jury had been denied U.S. Supreme Court granted certiorari and consolidated the cases

Issue ●

Whether there is a right by the Due Process Clause to trial by jury in a juvenile court proceeding

Holding ●

The court affirmed the judgements that adjudicated several juveniles delinquent without a jury trial and held that there was no constitutional right to a jury trial in juvenile court

Reasoning ●

The Supreme Court affirmed the judgments because the right to trial by jury in the adjudicative phase of a state juvenile court delinquency proceeding was not guaranteed by the Due Process Clause of U.S. Constitutional amendment XIV.

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The Court distinguished the nature and purpose of the juvenile court proceeding from a criminal proceeding and noted that all rights constitutionally assured for the adult accused had not traditionally been imposed upon the state juvenile proceeding.

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The Court found that the applicable due process standard in both proceedings was fundamental fairness.

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To that end, the Court noted the requirements of notice, counsel, confrontation, crossexamination, and standard of proof in juvenile proceedings.

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However, the Court determined that the legal system did not always regard a jury as a

necessary component of accurate fact-finding and noted that juries were not required in equity, workmen's compensation, probate, or deportation cases. ●

The Court concluded that trial by jury in the juvenile court's adjudicative stage was not a constitutional requirement.

E.J. v. State (2005) Facts ● ●

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E.J. appeals her adjudication of delinquency and disposition for obstructing or opposing an officer with violence On June 2, 2004, the trial court placed defendant on juvenile probation for a term not to exceed one year and imposed costs as a condition of probation of, inter alia (among other things), $3 pursuant to Fla. Stat. ch. 938.19 ○ https://advance.lexis.com/document/documentlink/? pdmfid=1000516&crid=1cc565ef-7f33-48f0-959c-3177b57524b7&pddocfullpath= %2Fshared%2Fdocument%2Fstatutes-legislation%2Furn%3AcontentItem %3A5C24-MXC1-6SKW-D4BC-0000000&pdcontentcomponentid=6258&pddoctitle=Fla.+Stat.+ch. +938.19&pdproductcontenttypeid=urn%3Apct %3A83&pdiskwicview=false&ecomp=v311k&prid=cc1189d2-da59-4b1e-8a03777b11d5031b E.J. filed a notice to appeal and later filed a motion to correct sentencing error pursuant to Florida Rule of Crim Pro 3.800(b) ○ In her motion, E.J. challenged section 938.19 which contains general prohibition on imposing “court fees” in any proceeding under chapter 985 against “any party to a deliquency petition or any parent or legal guardian” ○ She argued that because section 938.17 and 938.19 did not expressly apply to juvenile cases, the court should strike those costs Trial court denied the motion The appellate court held that Florida Statute did not specifically authorize the imposition of the $3 cost in juvenile delinquency cases Further, juveniles were not deemed to be “convicted” by adjudications of delinquency Because the defendant was not convicted and because the statute did not provide for imposition of the cost upon adjudication of delinquency, imposition of $3 was improper

Issue ●

Should the court fees apply

Holding ●

The adjudication of delinquency was affirmed ○ But the case was remanded for the trial court to strike the imposition of ac ost for teen court

Reasoning ● ●

Further, juveniles were not deemed to be “convicted” by adjudications of delinquency Because the defendant was not convicted and because the statute did not provide for imposition of the cost upon adjudication of delinquency, imposition of $3 was improper

State v. Menuto (2005) Facts ● ●

Charge against Menuto was based on a 1996 incident where Menuto entered a dwelling

Waiver of Rights. I understand that I have all of the rights below and that by admitting the charge(s) in the petition, or pleading no contest, I will not have a trial or hearing and I will give up all of these rights: ● ● ● ● ● ●

The right to a speedy court trial or hearing where the judge would listen to all the evidence and decide if the district attorney has enough evidence to prove that I did what the petition says I did. The right to see, hear, and have my attorney question witnesses, including the officer who wrote the report, and any of the people who provided information that is written in the report. The right to testify or speak up for myself in court. The right to be silent and not say anything that might hurt myself or my case. The right to have witnesses come to court, even if they don't want to, and talk to the judge about my case. The right to appeal, or ask another court to look at, decisions by the judge that I disagree with.

Roper v. Simmons (2005) Facts ● ●

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Christopher Simmons, 17, planned a murder and spoke about it with two of his friends, Charles Benjamin (15) and John Tessmer (16) Simmons proposed to commit burglary and murder by breaking and entering, tying up a victim, and throwing the victim off a bridge ○ Simmons assured his friends they could “get away with it” because they were minors The three boys met at 2 a.m. on the night of the murder, but Tessmer left ○ The state later charged Tessmer with conspiracy, but dropped the charge in exchange for his testimony against Simmons Simmons and Benjamin entered the home of victim Shirley Crook, through an open window and unlocking the back door Simmons turned on the hallway light, Mrs. Cook “who’s there?” Simmons entered Mrs. Cook’s bedroom - he recognized her from a previous car accident involving them both ○ Simmons later admitted this confirmed his resolve to murder her Simmons used duct tape to cover her eyes and mouth and bind her hands ○ Simmons and Benjamin put her in minivan and drove to a state park Mrs. Cook’s head was covered with a towel and walked to a railroad ○ They tied her hands and feet together with electrical wire, wrapped her whole face in duct tape and threw her from the bridge, where she drown On September 9, Mrs. Cook’s husband returned from an overnight trip, found the bedroom in disarray, and reported his wife missing ○ On the same afternoon, fishermen recovered the victim’s body from the river Simmons was bragging about the killing, telling his friends he had killed a woman “because the bitch seen my face” The next day police arrested Simmons at his high school and took him to the police station ○ They read him his Miranda rights, Simmons waived his right to an attorney and agreed to answer questions After less than 2 hours of interrogation, Simmons confessed to the murder and agreed to perform a videotaped reenactment at the crime scene State charged Simmons with burglary, kidnapping, stealing, and murder in the first degree As Simmons was 17 at the time of the crime, he was outside the criminal jurisdictional of Missouri’s juvenile court system ○ He was tried as an adult

Procedural Summary ●

At State sought the death penalty

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The State submitted that the murder was committed for the purpose ■ of receiving money ■ Avoiding, interfering with, or preventing lawful arrest of the defendant ■ Involved depravity of mind and was outrageously and wantonly vile, horrible, and inhuman ● The jury recommended the death penalty after finding the State had proved each of the 3 aggravating factors (above) ○ Trial judge imposed the death penalty ● Missouri court decided, 6 to 3, using the reasoning from the Atkins case that the execution of minors was now unconstitutional On Appeal to the U.S. Supreme Court ● The government argued that allowing a state court to overturn a Supreme Court decision by looking at “evolving standards” would be dangerous, because state courts could just as easily decide that executions prohibited by the Supreme Court

Issue ●

Does the execution of minors violate the prohibition of “cruel and unusual punishment” found in the 8th Amendment and applied to the states through the incorporation doctrine of the 14th Amendment

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Yes. 5-4 opinion. They look at the statutes of the states to see what the states are doing

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The Court ruled that standards of decency have evolved so that executing minors is “cruel and unusual punishment” prohibited by the 8th Amendment The majority cited a consensus against the juvenile death penalty among state legislatures, and its own determination that the death penalty is a disproportionate punishment for minors Most limited and most deserving Finally the Court pointed to “overwhelming” international opinion against the juvenile death penalty

Dissent ● ● ●

Must look to whether such punishment is consistent with contemporary standards of decency We are obligated to weigh both the objective evidence of societal values and our own judgment as to whether death is an excessive sanction in the context at hand Here, the objective evidence is inconclusive ○ Standing alone it does not demonstrate that our society has repudiated capital

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punishment of 17 year old offenders in all cases Rather the actions of the Nation’s legislatures suggest that, although a clear and durable national consensus against this practice may in time emerge, that day has yet to arrive

Graham v. Florida (2010) Facts ●

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Terrance Graham was born on 1/6/87 ○ Graham’s parents were addicted to crack cocaine, and their drug use persisted in his early years Graham was diagnosed with ADHD in elementary school ○ He began drinking alcohol and using tobacco at age 9 and smoke marijuana at age 13 When Graham was 16, he and three other youths attempted to rob a BBQ restaurant in Jacksonville, Florida One youth, who worked at the restaurant, left the back door unlocked just before closing time Graham and another youth entered through the back door wearing masks ○ Graham’s accomplice struck the restaurant manager twice in the back of the head with a metal bar The manager started yelling at both boys and they ran out and escaped in a car driven by the third accomplice ○ The restaurant manager required stitches for his head injury ○ No money was taken Graham was arrested for the robbery attempt Under Florida law, it is within a prosecutor’s discretion whether to charge 16 and 17 year olds as adults or juveniles for most felony crimes ○ Fla. Stat. §985.227(1)(b) (2003) Graham’s prosecutor elected to charge Graham as an adult ○ Charges were armed burglary with assault and battery ■ A first degree felony carrying a maximum penalty of life imprisonment without the possibility of parole ○ Attempted armed robbery ■ Second degree felony carrying a maximum penalty of 15 years imprisonment Graham pleaded guilty to both charges under a plea agreement ○ Graham wrote a letter to the court stating it was his first and last time getting in trouble...decided to turn his life around...made a promise to God and himself for a second chance and to do whatever it takes to get the NFL The trial court accepted the plea agreement

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Court withheld adjudication of guilt as to both charges and sentenced Graham to concurrent 3-year terms of probation Graham was required to spend the first 12 months of his probation in the county jail, but he received credit for the time he had served awaiting trial and was released on 6/25/04 On 12/2/04 Graham was arrested again ○ Home invasion robbery, with two accomplices (Meigo Bailey (20) and Kirkland Lawrence (20)) ○ Forcibly entered the home and held pistol’s to Rodriguez’s chest ○ For the next 30 minutes, the 3 held Rodriguez and another man at gunpoint while they ransacked the home searching for money ○ Before leaving, Graham and his accomplices barricaded Rodriguez and his friend inside a closet ○ It was alleged that Graham, Bailey, and Lawrence later that evening attempted a second robbery, during which Bailey was shot ○ Graham, with his father’s car, drove Bailey and Lawrence to the hospital and left them there ○ As Graham drove away, a police sergeant signaled him to stop ■ Graham continued at a high speed but crashed into a telephone pole ■ He tried to flee on foot but was caught ■ Three handguns were found in his car Graham denied involvement of the crimes ○ He said he encountered Bailey and Lawrence only after Bailey had been shot ○ Graham later told the detective that he had been involved in 2 or 3 robberies prior to that night On 12/13/04, Graham’s probation officer filed an affidavit with the trial court stating that Graham had violated the conditions of his probation by ○ Possessing firearms ○ Committing crimes ○ Associating with persons engaged in criminal activity Graham maintained that he had no involvement in the home invasion robbery ○ But he did admit to violating probation by fleeing

Procedural Summary ●

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Under FL law, the minimum sentence Graham could received, unless the judge felt otherwise, was 5 years imprisonment ○ Maximum was life imprisonment State recommended 30 years for armed robbery and 15 years on the attempted armed robbery Trial court found Graham guilty of the earlier armed robbery and attempted armed robbery charges ○ Sentenced Graham to life imprisonment for the armed robbery and 15 years on the attempted armed robbery Graham filed a motion in the trial court challenging his sentence under the 8th

Amendment ○ Motion was deemed denied after the trial court failed to rule on it within 60 days

Issue ●

Does the imposition of a life sentence without parole on a juveni...