Articles Posted in Juvenile Law

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The State appealed the magistrate court's dismissal of the State's motion for contempt brought against Luis Juarez for failing to make payments ordered in a juvenile proceeding. In 2002, Juarez admitted to committing an offense that would have been a misdemeanor if he had been an adult. Much time passed and the court entered several orders directing Juarez to pay fees and restitution in varying sums. Eventually, on October 6, 2005, the magistrate court entered its Amended Financial Judgment and Order directing Juarez to pay restitution. Juarez failed to pay, and would fail to appear twice, resulting in bench warrants for his arrest being issued both times. By the second time Juarez came before the magistrate judge, he was over 26-years old, and outside of the juvenile court's jurisdiction. The court reasoned that now that Juarez had been brought in for an adult felony charge, it could no longer hear the contempt proceedings for failing to pay restitution. The district court reasoned that contempt was not available to compel payment of a restitution obligation arising from a proceeding under the JCA because the magistrate court's jurisdiction was conveyed by operation of Idaho Code section 20-505 and withdrawn by operation of Idaho Code section 20-507. The Supreme Court reversed the district court, concluding: (1) the magistrate court had jurisdiction over a charge of misdemeanor contempt under Idaho Code section 18-1801 (and if the offender was under eighteen years of age at the time of the criminal contempt, and the juvenile court exercises its discretion to treat the offense under the JCA, then Idaho Code section 20-507 would operate to terminate the juvenile court's jurisdiction as the proceedings would arise out of the JCA); (2) based on the State's own affidavit, the alleged crime was committed more than four years before these proceedings were commenced; (3) although this action was processed as a criminal case, no complaint was ever filed; (4) despite the lack of a complaint and without a finding of probable cause, the magistrate court issued warrants which resulted in Juarez's arrest; (5) the court's written "Statement of Rights and Explanation of Procedures for Contempt of Court" erroneously advised Juarez that the State bore the burden of proving the contempt "by a preponderance of the evidence;" (6) the court erroneously advised Juarez of the potential penalties upon conviction for misdemeanor contempt (18-1801 did not prescribe the penalty for misdemeanor contempt); (7) the magistrate court did not appear to recognize that Juarez had a right to a jury trial for misdemeanor contempt; and (8) Juarez appeared before the court without counsel, and Juarez discussed his case with the prosecutor without a knowing and voluntary waiver of the right to the assistance of counsel. The Supreme Court reversed the district court's decision affirming the magistrate court's order dismissing the State's motions for contempt. The case was remanded for further proceedings. View "Idaho v. Juarez" on Justia Law

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Andrew Garcia admitted to committing an offense that would have been a misdemeanor if he were an adult. He was ordered to pay court costs of $20.00. After Garcia admitted to committing another offense and a probation violation, he was ordered to pay court costs, probation fees, and community service fees. On May 10, 2010, Garcia admitted to committing another offense and was once again ordered to pay court costs and probation supervision fees. After he failed to make those payments, the State filed a motion for contempt. The magistrate court dismissed the motion, concluding that it did not have jurisdiction because Garcia was then over twenty-one and juvenile court jurisdiction was terminated by operation of Idaho Code section 20-507. The State appealed and the district court affirmed the magistrate court’s order. The State appealed the decision of the district court. After review, the Supreme Court concluded the trial court possessed the inherent power to adjudicate Garcia's alleged contempt, and incorrectly dismissed the State's motion for contempt for lack of jurisdiction. The district court was reversed and the case remanded for further proceedings. View "Idaho v. Garcia" on Justia Law

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The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court. View "Idaho v. John Doe (2012-10)" on Justia Law

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In 2009, the State filed a petition against John Doe, charging that he was within the purview of Idaho's Juvenile Corrections Act (JCA) for delivery of a schedule III controlled substance, hydrocodone. The State and Doe's counsel reached an agreement whereby Doe admitted to the charge and, in exchange, the State waived proceedings to bring Doe into adult court. At the conclusion of Doe's sentencing hearing, the magistrate judge memorialized his ruling in a "decree" that was issued that same day. The decree stated, "It is hereby Ordered, Adjudged and Decreed that [Doe] is within the purview of the [JCA] and shall be placed on Formal Probation supervision not to exceed 2 years." In the first year of Doe's probation, he had two probation review hearings, both of which demonstrated good behavior. At Doe's one-year probation review hearing, Doe's counsel argued that the magistrate should convert his formal probation to an informal adjustment. Doe's counsel could not cite any authority for converting the sentence, but believed that the court had broad authority to do so based on the interests of justice. The State objected and argued that the court did not have authority to convert the formal probation to an informal adjustment. Ultimately, the magistrate court stated that it had the authority to convert the sentence and entered a "supplemental decree nunc pro tunc to date of original order," granting Doe an informal adjustment and dismissing the case. The magistrate then issued an Order Supplementing Decree that provided "Formal Probation converted to Informal Adjustment, nunc pro tunc 05/05/09." The State filed an appeal to the district court. The district court affirmed the magistrate court's order. The State timely appealed to the Supreme Court. Because it was improper for the magistrate to convert Doe's sentence, any subsequent dismissal or termination of the improperly substituted informal adjustment could not be upheld. The Supreme Court reversed the district court's order and remanded the case for reinstatement of the 2009 decree. View "Idaho v. Doe (2012-09)" on Justia Law