Week 4 Cases - Lecture notes 4 PDF

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Week 4 Cases In re Gault (1967) Summary: ● Gerald Gault (15) was taken into custody after a complaint of him making lewd telephone calls ● Juvenile court committed him to the State Industrial School as a juvenile delinquent ● Gerald’s father appeals through state courts on habeas corpus → challenging the constitutionality of the Arizona Juvenile Code and procedure used during his son’s case Ruling: ● State Supreme Court held that the Arizona Juvenile Court didn’t uphold due process and did not adequately give written notice to the child and his/her parents/guardian ● Child also must be advised of their right to be represented by counsel and right to remain silent In re George T (2004) Summary: ● 15 year old George, high school student in Santa Clara, wrote a poem and handed it to a classmate named Mary and told her to read them → this case examines if the poem made a criminal threat ● The poem included a line about bringing guns to kill students at school ● Mary notified her English teacher and the teacher notified the school, George was taken into custody ● Juvenile court ordered 100-day commitment in juvenile hall ● Minor appealed saying there was not sufficient evidence to support that it was a criminal threat → Court of Appeal affirmed judgement Ruling: ● Reversed the rule → court concluded that the poem was ambiguous and the circumstances failed to establish that the poem constituted a criminal threat

Roper v. Simmons (2005) Summary: ● Simmons (17) planned and committed capital murder, sentenced to death after he turned 18 ● Simmons appealed and Missouri Supreme Court agreed and set aside death sentence in favor of life imprisonment without possibility of release Ruling: ● Held → 8th (prohibits cruel and unusual punishments) and 14th amendments forbid imposition of death penalty on offenders who were under the age of 18 when their crimes were committed ● Court sees death penalty as a disproportionate punishment for those under 18

McKeiver v. Pennsylvania (1971)

Summary: ● McKeiver and Terry were teenagers charged with robbery, theft, assault, and escape and were denied a request for a jury trial at the juvenile court of Philadelphia ● Appellants were not given a trial by jury ● State Supreme Court held that there is no constitutional right to a jury trial in juvenile court but appellants argue for jury trial because they were tried in proceedings very similar to those of a criminal trial (press and members of public were at the trial) Ruling: ● Held: A trial by jury is not constitutionally required in the adjudicative phase of state juvenile court delinquency proceeding Graham v. Florida (2009) Summary: ● Graham (16) committed armed burglary ● Florida trial court sentenced Graham to probation and withheld adjudication of guilt ● Graham then committed additional crimes and violated terms of his probation so the trial court adjudicated Graham guilty of the earlier charges, revoked his probation, and sentenced him to life in prison for the burglary (without parole) ● Graham challenged the sentence under the 8th amendment’s cruel and unusual punishments clause but the state first district court of appeal affirmed Ruling: ● Held: 8th Amendment clause does not permit a juvenile offender to be sentenced to life in prison without parole for a non homicide crime Sullivan v. Florida (2010) Summary: ● Joe Sullivan committed sexual battery when he was 13 years old and was sentenced to life in prison in Florida with no possibility of parole - Sullivan also had an extensive criminal history so court felt an adult sentence was appropriate ● Same issue as Graham v. Florida → sentencing a juvenile to life imprisonment without parole violates 8th amendment’s cruel and unusual punishment clause Ruling: ● US Supreme court let the lower court’s decisions stand Jackson v. Hobbs (2011) Summary: ● Kuntrell Jackson (14) sentenced to life in prison without possibility of parole for felonymurder when his cousin killed a shop attendant during a robbery in Arkansas ● Arkansas supreme court affirmed Jackson’s conviction and state court denied his petition for habeas corpus where he argued that life sentence for 14 year old was cruel and unusual under 8th amendment Ruling: ● Court ruled that juvenile offenders have diminished culpability and greater prospects for reform and reversed the life sentence Miller v. Alabama (2012) Summary: ● Evan Miller (14) had been in and out of foster care because his mother suffered from alcoholism and drug addiction

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Miller also abused drugs and alcohol and had attempted suicide 4 times Miller stole a wallet a drug dealer and beat him up/lit a fire and he ended up dying from these injuries Alabama ended up trying him as an adult and charged him with murder and arson → sentenced to life without parole

Ruling: ● Reversed ● Court says that, yes, the imposition of a life-without-parole sentence on a fourteen-yearold child violates the Eighth and Fourteenth Amendments' prohibition against cruel and unusual punishment...