Juvenile Law Cases
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Juvenile Law

WyomingCriminalJuvenile LawStatutory Interpretation
Wyoming Supreme Court
Uncategorized

In the Interest of RCR — Wyoming Boys’ School Cannot Hold Alleged Delinquents Before Adjudication

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The Wyoming Supreme Court reversed a contempt order against the Wyoming Boys’ School for refusing to admit an alleged delinquent juvenile before adjudication. The court held that Wyoming law expressly prohibits pre-adjudication placement at WBS, which is a reformatory for adjudicated delinquents — not a juvenile detention facility — and that the juvenile court abused its discretion by ordering such placement. All three exceptions to the mootness doctrine applied, allowing the court to reach the merits despite the case having been resolved below.

North CarolinaFamily LawJuvenile LawParental Rights
North Carolina Court of Appeals
Uncategorized

In re: J.Q. — Trial Court Lacked Authority to Cease Reunification Efforts at Review Hearing; Permanency Planning Hearing Required

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The North Carolina Court of Appeals vacated an order ceasing a mother’s reunification efforts because the trial court entered that order at a review hearing rather than a permanency planning hearing, holding that N.C.G.S. § 7B-906.1(d1) does not authorize courts to cease reunification at review hearings—that authority belongs exclusively to permanency planning hearings under § 7B-906.2(b)—while also cautioning that missed 30-day permanency planning hearing deadlines must be challenged by writ of mandamus, not appeal.

North CarolinaAppellate ProcedureChild CustodyJuvenile Law
North Carolina Court of Appeals
Uncategorized

In re J.Q. — Trial Court Erred by Ceasing Reunification Efforts at Review Hearing; Only Permanency Planning Hearings Authorize That Step

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The North Carolina Court of Appeals vacated a review-hearing order ceasing reunification efforts, holding that N.C.G.S. § 7B-906.2(b) reserves that power exclusively for permanency planning hearings; the trial court’s failure to schedule a permanency planning hearing within the statutory thirty-day window was an error but not prejudicial on appeal, with mandamus the proper real-time remedy.

UtahFamily LawIneffective Assistance of CounselJuvenile Law
Court of Appeals of Utah
Uncategorized

In re A.H. — Utah Court of Appeals Again Vacates TPR Order After Finding All Three of Father’s Trial Attorneys Rendered Ineffective Assistance

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For the third time, the Utah Court of Appeals vacated an order terminating Father’s parental rights as to two young children, holding that all three of his trial attorneys — retained counsel and two appointed counsel — rendered ineffective assistance by failing to file pretrial disclosures and seek a continuance, depriving Father of the ability to call sibling witnesses whose testimony bore directly on the best-interest determination; the court also held that Utah’s IAC right extends to retained attorneys who never formally enter an appearance.

MichiganFamily LawJuvenile LawParental Rights
Michigan Court of Appeals
Uncategorized

In re Gilliam Minors — Relative Placement with Biological Father Requires Explicit Best-Interest Analysis Before Termination

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The Michigan Court of Appeals affirmed termination of a mother’s parental rights to her youngest child but vacated the termination as to the oldest child, holding that the trial court failed to expressly consider the oldest child’s relative placement with her biological father—an explicit statutory factor that weighs against termination and must be addressed on the record before a best-interest determination can stand.

North CarolinaFamily LawJuvenile Law
North Carolina Court of Appeals
Uncategorized

In re: J.E.S., P.K.S., P.E.S. — Termination of Parental Rights Affirmed Where Psychological Evaluation Shows Persistent Incapacity and Prior History Predicts Future Neglect

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The North Carolina Court of Appeals affirmed termination of parental rights on neglect grounds as to three children removed after a nighttime car accident left two infants with traumatic brain injuries, holding that the mother’s extensive CPS history, prior criminal conviction for a child’s death, psychological diagnosis showing parenting incapacity, and continued unsafe conduct during supervised visits established the likelihood of future neglect required by N.C. Gen. Stat. § 7B-1111(a)(1).

GeorgiaAppellate ProcedureCriminalJuvenile Law
Uncategorized

State v. Jones — Court Affirms Transfer to Juvenile Court After State’s Ex Parte Extension Order Invalidated

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The Georgia Court of Appeals affirmed the transfer of a juvenile murder case to juvenile court, holding that the State’s ex parte 90-day extension of the 180-day indictment deadline under OCGA section 17-7-50.1(a) was invalid because the State failed to provide notice, hold a hearing, or demonstrate good cause as the statute requires.

OhioFamily LawJuvenile Law
Ohio Court of Appeals (Second District)
Uncategorized

In re Adoption of M.K.B.B. — Second District affirms that mother’s consent to adoption was not required

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The Second District affirmed that a biological mother’s consent was not required for adoption of her two children by their paternal great-aunt, finding clear and convincing evidence that the mother had failed to maintain contact with or provide support for the children during the year preceding the petition.

OhioEvidenceFamily LawJuvenile Law
Ohio Court of Appeals (Eighth District)
Uncategorized

In re Q.M.B. — Eighth District affirms temporary custody to CCDCFS where mother’s pattern of conduct supported neglect and dependency findings

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The Eighth District affirmed temporary custody of an infant to CCDCFS, finding clear and convincing evidence of neglect based on the mother’s pattern of conduct including threats while holding the child, a prior child’s neglect adjudication, and refusal to engage in case-plan services.

OhioConstitutionalCriminal LawJuvenile Law
Ohio Court of Appeals (Eighth District)
Uncategorized

In re J.W. — Eighth District reverses denial of mandatory bindover, holds juvenile’s own confession established probable cause for firearm display during robbery

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The Eighth District reversed the juvenile court’s denial of mandatory bindover, holding that a juvenile’s own recorded confession admitting he ‘put a gun on’ a victim established probable cause for the firearm display element without requiring victim testimony.

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