Justia U.S. 8th Circuit Court of Appeals Opinion SummariesArticles Posted in Juvenile Law
United States v. Barraza
Defendant was convicted of kidnapping Maria Eloiza and her five-year-old son, resulting in the deaths of both. Defendant was 16-years-old at the time he committed the offense, and the district court sentenced him to the statutorily mandated term of life imprisonment. The Supreme Court subsequently held in Miller v. Alabama, 567 U.S. 460, 465 (2012), that a mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments. Based on Miller, the district court granted defendant's motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. After the district court sentenced defendant to 50 years' imprisonment, defendant appealed.The Eighth Circuit affirmed, holding that the district court did not clearly err in finding defendant competent to proceed with resentencing. In this case, the district court was entitled to base its competency determination on the BOP doctor's psychological evaluation concluding that defendant had been restored to competency. The court also held that the district court did not plainly err by calculating an advisory Guidelines range of life imprisonment under USSG 2A1.1; the district court considered the 18 U.S.C. 3553(a) sentencing factors, including defendant's youth; and defendant's sentence, a downward variance from the Guidelines range of life, was not substantively unreasonable. View "United States v. Barraza" on Justia Law
Ali v. Roy
Ali shot and killed three people during an attempted robbery in Minneapolis. He was given three consecutive life sentences, each permitting his early release after 30 years so that Ali must remain in prison for at least 90 years. Relying on recent Supreme Court precedent, Ali argued that the Eighth Amendment forbids life-without-parole sentences for juvenile defendants unless they are irreparably corrupt and that a sentencing court must conduct a hearing to consider the juvenile defendant’s youth as a mitigating factor before imposing a life-without-parole sentence. Ali claimed his sentence was the “functional equivalent” of life-without-parole. The Minnesota Supreme Court rejected Ali’s argument. The Eighth Circuit affirmed the denial of Ali’s petition for habeas relief under 28 U.S.C. 2254. Ali’s case is distinguishable from the Supreme Court cases; Ali received three life sentences for three separate murders, each permitting possible release. Ali does not face a life-without-parole sentence and the Supreme Court has not “clearly established” that its ruling apply to consecutive sentences functionally equivalent to life-without-parole. View "Ali v. Roy" on Justia Law
United States v. Juvenile Male
The Eighth Circuit affirmed the district court's order transferring defendant for criminal prosecution as an adult under 18 U.S.C. 5032. The court held that the district court did not abuse its discretion by deciding to transfer where the district court made specific findings with respect to each statutory factor. In this case, the juvenile's age, nature of the offenses, his role in the offenses, and his intellect and maturity weighed in favor of transfer. The court also held that it was not required to hold an evidentiary hearing where the district court accepted the magistrate judge's credibility findings and independently weighed the statutory factors. View "United States v. Juvenile Male" on Justia Law
United States v. Gauld
The Eighth Circuit granted en banc review and held that a state juvenile delinquency adjudication is a "prior conviction" under 18 U.S.C. 2252(b)(1). The en banc court held that, because federal law distinguishes between criminal convictions and juvenile delinquency adjudications, and because section 2252(b)(1) mentions only convictions, juvenile delinquency adjudications do not trigger that statute's 15-year mandatory minimum sentence. Accordingly, the en banc court vacated defendant's sentence and remanded for resentencing. View "United States v. Gauld" on Justia Law
A.W. v. Wood
The Eighth Circuit held that Nebraska's Sex Offender Registration Act (SORA), Neb. Rev. Stat. 29-4003(1)(a)(iv), did not apply to A.W., as a juvenile delinquent that engaged in conduct constituting first-degree criminal sexual conduct in Minnesota. Under both Minnesota and Nebraska law, an adjudication of delinquency was not a criminal proceeding, nor did it result in a conviction; the plain and ordinary meaning of "sex offender" was to be ascertained with respect to Nebraska law; and "sex offender" was ordinarily understood as a person who has been convicted of a crime involving unlawful sexual conduct. View "A.W. v. Wood" on Justia Law
Bradford v. Avery
The Eighth Circuit reversed and remanded the district court's grant of summary judgment in a suit against employees of a juvenile home, concluding that the district court erred by holding as a matter of law that defendants were entitled to qualified immunity. Plaintiff alleged that defendants violated his constitutional rights by housing him in prolonged solitary confinement, failing to educate him, and allowing him to be sexually abused. In this case, the district court addressed only the fact of juvenile court supervision in determining that defendants were entitled to qualified immunity, and its opinion did not contain sufficient detail to allow the court to review whether defendants were entitled to qualified immunity. View "Bradford v. Avery" on Justia Law
United States v. E.T.H.
Defendant, originally adjudicated a juvenile delinquent for assault of a federal officer, appealed the district court's imposition of a combination of official detention and juvenile delinquent supervision following revocation of his prior supervision term. Defendant argues that the total combined term of detention and supervision exceeds the maximum possible term under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031 et seq. The court agreed and held that the maximum term of supervision that a court may impose under section 5037(d)(6) is determined by the requirements in section 5037(d)(2), using the juvenile's age at the time of the revocation hearing. As a result, the maximum total period of detention and supervision that may be imposed upon revocation of a previously imposed term of supervision for a juvenile who is under age 21 at the time of revocation is (i) 3 years, (ii) the top of the Guidelines range that would have applied to a similarly situated adult defendant unless the court finds an aggravating factor to warrant an upward departure, or (iii) the maximum term of imprisonment that would be authorized if the juvenile had been tried and convicted as an adult, whichever is least, "less the term of official detention ordered." Accordingly, the court reversed and remanded with instructions. View "United States v. E.T.H." on Justia Law
Thompson v. Roy
In 2009, a jury found Thompson guilty of two counts of first-degree premeditated murder and two counts of first-degree murder while committing aggravated robbery. Thompson was 17 when he committed the crimes. Pursuant to Minnesota law, he received two consecutive mandatory sentences of life imprisonment without the possibility of release. The Minnesota Supreme Court affirmed Thompson’s convictions and sentences on direct appeal. In 2012, the U.S. Supreme Court (Miller decision) held that the Eighth Amendment forbids a sentencing scheme that mandates a sentence of life in prison without the possibility of parole for juvenile offenders. Thompson sought relief under 28 U.S.C. 2254. The district court dismissed with prejudice, finding that Miller’s rule was not retroactively applicable. The Eighth Circuit affirmed. Miller did not announce a new substantive rule because it neither categorically barred a punishment nor placed a group of persons beyond the state’s power to punish. After Miller, as before, a court retains the power to impose a life sentence without the possibility of parole. That the sentence now must be discretionary does not alter its substance. View "Thompson v. Roy" on Justia Law
Martin v. Symmes
A Minnesota jury convicted Martin of first-degree murder, committed at age 17. Martin received a mandatory life sentence without possibility of release. The Minnesota Supreme Court affirmed and rejected a challenge to the jury’s composition under Batson. Martin filed a habeas petition under 28 U.S.C. 2254. While it was pending, the U.S. Supreme Court held that mandatory life sentences without parole for defendants who commit homicide before age 18 violate the Eighth Amendment. Martin argued that Miller applied retroactively to him. The district court denied the petition. The Eighth Circuit affirmed. Miller does not apply retroactively on collateral review. The Minnesota Supreme Court did not unreasonably determine that the trial court properly rejected Martin’s Batson challenge. View "Martin v. Symmes" on Justia Law
D.J.M., et al. v. Hannibal Public Sch. Dist., et al.
D.J.M., a student in the Hannibal Public School District #60 (district), sent instant messages from his home to a classmate in which he talked about getting a gun and shooting some other students at school. After D.J.M. was subsequently suspended for ten days and later for the remainder of the school year as a result of his actions, D.J.M.'s parents sued under 42 U.S.C. 1983, alleging that the district violated D.J.M.'s First Amendment rights. At issue was whether the district court properly granted summary judgment to the district on D.J.M.'s constitutional claims and remanded his state claim for administrative review. The court held that D.J.M. intentionally communicated his threats to a third party and the district court did not err in finding that they were true threats. The court also held that true threats were not protected under the First Amendment and the district was given enough information that it reasonably feared D.J.M. had access to a handgun and was thinking about shooting specific classmates at the high school. Therefore, in light of the district's obligation to ensure the safety of its students and reasonable concerns created by shooting deaths at other schools, the district court did not err in concluding that the district did not violate the First Amendment by notifying the police and subsequently suspending him after he was placed in juvenile detention. The court further held that it was reasonably foreseeable that D.J.M.'s threats would be brought to the attention of school authorities and created a risk of substantial disruption within the school environment. The court finally held that it was not an abuse of discretion to dismiss the state law claim as moot. Accordingly, the judgment of the court was affirmed.