Sample Jury Instruction on Unlawful Use of Physical Force by Facility Staff
Sample jury instructions outlining when physical force is by facility staff is unlawful against a young person.
Read MoreSample Motion for Court Order Allowing Defense Counsel Access to the Scene for Evidence Collection
A sample motion in a youth facility assualt case asking the court to order access to the facility for evidence collection, including viewing the scene and taking photographs of the facility.
Read MoreSample Motion for Court Order Allowing Defense Counsel Access to Youth Facility for Evidence Collection
A sample motion requesting the court to compel Colorado’s Department of Youth Services to comply with a subpoena duces tecum regarding records related to excessive force and physical abuse in their facilities.
Read MoreSample Motion for Subpoena Duces Tecum Or Order to Compel to the Division of Youth Services Regarding Discoverable Material Related to a Physical Restraint Incident
A sample motion asking the Court to issue a subpoena duces tecum to the state youth department for material reports, documents, witness information, and video survelliance regarding an incident of physical restraint.
Read MoreSample Jury Instruction on Adolescent Brain Development and Impulsivity in a Self-Defense Case
Sample jury instructions on adolescent development in a self-defense case involving staff at a youth facility.
Read MoreHuman Rights Watch, et al. Amicus Brief, O.G. v. Superior Court
This amicus brief supporting the petitioner O.G. asks the California Appellate Court to uphold the passage of SB 1391, which eliminated transfer of 14- and 15- year old to adult court. The amicus brief outlines why the law ensures age-appropriate services for young people as well as protecting public safety by reducing recidvisim and strengthening…
Read MoreSample Motion Opposing Transfer Under Tennessee’s Transfer Statute
This sample motion from Tennessee outlines why transfer is unconstitutional in Tennessee under the 8th Amendment of the U.S. Constitution, and Tennessee’s purpose clause. The brief highlights Supreme Court jurisprudence, scientific and medical research, and evolving standards of decency.
Read MoreSample Motion for Alternative Disposition
This sample motion from Oregon argues for an alternative disposition to an 18-month probation period. Noting the harms of surveillance and the heightened impact it has on the health and wellbeing of Black and Latine youth, this motion proposes a 6 month conditional postponement period instead that would give youth an opportunity to demonstrate that…
Read MoreWorksheet: Youth Defender Agency/Office Audit
This resource is part of the Youth Defender Advocacy Program (YDAP) curriculum, a specialized trial advocacy training program for youth defenders. For sample completed worksheets, please contact us.
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