Unit V: Significant U.S. Supreme Court Rulings and the Impact on the Juvenile Justice System in America
Introduction We are now starting Unit V: Significant U.S. Supreme Court Rulings and the Impact on the Juvenile Justice System in America. So far, we have covered and discussed the historical background of juvenile delinquency and the juvenile justice system in the United States, criminological theories that help to expand our understanding of juvenile delinquency, the complex relationship between police officers and juveniles, juvenile gangs, and key actors that help play crucial roles as they relate to the structure of the juvenile court system.
Unit V: U.S. Supreme Court Rulings If you will recall, you learned about juvenile defense attorneys, juvenile prosecuting attorneys, and the juvenile court judge in the previous unit. In this unit, you will take what you have learned and expand your knowledge, exploring U.S. Supreme Court cases that helped define and direct juvenile corrections, juvenile defense attorneys, juvenile prosecuting attorneys, and juvenile court judges.
Unit V: U.S. Supreme Court Rulings Before we begin, watch the video linked below that continues the story of Little John, a juvenile. https://online.columbiasouthern.edu/csu_c ontent/courses/emergency_services/bcj/bcj 2201/15K/video/unitv_video.mp4 Click here to access the transcript for this video.
Consider the Following You will want to start thinking about this question as you read through the following U.S. Supreme Court decisions and cases: How does this case directly relate to juvenile defense attorneys and juvenile court judges who preside over juvenile court cases?
Court Cases The information below provides a brief description of some of the cases we will explore. Figure 1: U.S. Supreme Court decisions impacting juvenile court system. ( U.S. Supreme Court Cases, 1999)
Kent v. United States So, let s begin by examining the first landmark case you will learn about: Kent v. United States. Before we can examine the case, we need to know the background and historical makeup of the case. In 1961, Morris Kent was a 16-year-old juvenile who was charged with rape and robbery. While in custody, Kent confessed to the criminal charges and crimes against him.
Kent v. United States Kent s defense lawyer filed a request for a judicial hearing as it related to the jurisdiction of the case. Jurisdiction means whether or not the case should be tried and take place in the locality and/or jurisdiction where the crime occurred or move the case to an alternative jurisdiction for a more fair and balanced trial. The juvenile court judge did not rule on this motion filed by Kent's attorney and entered a motion stating that the court was waiving jurisdiction after making a full investigation ( U.S. Supreme Court cases, 1999).
Kent v. United States Now, what is meant by full investigation is left up for interpretation. If you remember from a previous unit, judges often have a wide range of discretion in their courtroom. Kent was found guilty and sentenced to 30-90 years in prison. The main issue from the case is whether Kent was denied his constitutional rights because he was a minor. In appealing to the U.S. Supreme Court, Kent's attorney argued that the judge had not made a complete investigation and that Kent was denied constitutional rights simply because he was a minor ( U.S. Supreme Court cases, 1999).
In re Gault Another U.S. Supreme Court landmark decision is In re Gault. Let s look at the background of the In re Gault case. Gerald Gault, age 15, was accused of making an obscene phone call to his neighbor. After the call, Mrs. Cook filed a complaint with the local police department that resulted in Gerald s arrest and transport to a local juvenile detention center. The issue of lack of due process starts to unfold.
In re Gault At the time of the arrest related to the phone call, Gault s parents were at work and the arresting officer left no notice for them and did not make an effort to inform them of their son s arrest (United States Courts, n.d., para. 2). Next, we will see in even more detail how Gerald s due process rights were violated. At a hearing the next day, the complaining witness was not present, no sworn testimony was heard, no transcript was taken, nor testimony recorded (National Juvenile Defender Center, n.d.-a, para. 2).
In re Gault The judge presiding over the case decided to return Gerald to the juvenile detention center until he decided what to do with Gerald and the case. On June 15, 1964, the judge entered an order that Gerald was delinquent, mandating his incarceration in a residential facility until he turned 21 (National Juvenile Defender Center, n.d.-a, para. 2). After appealing to the Arizona Supreme Court and finally the U.S. Supreme Court, the decision on whether Gerald Gault s due process rights were violated was presented by the U.S. Supreme Court Judges.
In re Gault The In re Gault decision handed down from the U.S. Supreme Court mandated that juveniles are to be afforded the same constitutional rights as adults because juveniles are also U.S. citizens. These constitutional rights include, but are not limited to, the right to an attorney, the right to remain silent, the right to a formal notice of charges, and the right to a court hearing.
In Re Winship Another U.S. Supreme Court landmark case and decision we will examine is In re Winship. Again, let s examine the background of the case first. Samuel Winship, age 12, was accused of stealing $112 dollars from a woman s handbag. An employee at the time stated he had seen Samuel take the money from the woman s purse. However, other patrons and customers in the store at the same time claim the store employee was not in position to see the criminal act take place.
In Re Winship As students in criminal justice, you may start to think there may be reasonable doubt in this case. However, before the In re Winship decision, preponderance of the evidence was all that was needed to for a guilty verdict of juvenile delinquents. Now, as many of you already know, as it relates to criminal justice cases, proof beyond a reasonable doubt must be established for a guilty verdict to be presented. This was not always the case as it related to juvenile delinquents.
In Re Winship The In re Winship case was a landmark case in United States history because the U.S. Supreme Court ruled juveniles are also offered the same right. According to the National Juvenile Defender Center (n.d.-b), the Supreme Court held that for adjudications of delinquency, the standard of proof required is the same as for criminal cases (beyond a reasonable doubt) (para. 4).
McKeiver v. Pennsylvania, In re Terry, and In re Barbara Burrus In 1971, the U.S. Supreme Court issued a decision for McKeiver v. Pennsylvania, In re Terry, and In re Barbara Burrus. These cases were heard together to examine if the due process clause (right to jury trial) of the Fourteenth Amendment applies to juveniles. The Court held that juveniles do not have the right to a trial by jury. However, states may provide juveniles with jury trials.
McKeiver v. Pennsylvania, In re Terry, and In re Barbara Burrus McKeiver v. Pennsylvania Joseph McKeiver was 15 years old when charged with robbery, larceny, and receiving stolen goods ( McKeiver v. Pennsylvania, n.d.). He requested a jury trial. The request for a jury trial was denied. In re Terry Edward Terry was 16 years old when charged with assault and battery of a police officer ( McKeiver v. Pennsylvania, n.d.). He requested a jury trial. The request for a jury trial was denied In re Barbara Burrus This was a consolidated case that included more than 40 juveniles ( McKeiver v. Pennsylvania, n.d.). These juveniles had a range of charges and requested jury trials. The requests for jury trials were denied.
McKeiver v. Pennsylvania, In re Terry, and In re Barbara Burrus The ruling explained the following facets: Not all constitutional rights of adults should be given to juveniles. If the juvenile does receive a jury trial, it may be adversarial, which is in contrast to an informal, protective proceeding. A fair process does not necessarily include a jury trial. A jury trial could bring delays and formality to juvenile proceedings. Although the juvenile is not required to receive a jury trial, the judge may still use a jury in an advisory capacity.
Breed v. Jones Another landmark case is Breed v. Jones. Gary Jones, age 17, was charged with robbery and detained for a juvenile court hearing ( U.S. Supreme Court cases, 1999). The juvenile court hearing found the charges to be true, and at the disposition hearing, it was determined that the services of the juvenile court could not assist him ( U.S. Supreme Court cases, 1999). He was then waived to adult court that found him guilty of robbery. His counsel filed a writ of habeas corpus, arguing that waiving him to adult court constituted double jeopardy.
Breed v. Jones The court denied the petition and said that it was not double jeopardy because juvenile adjudication is not a trial. However, the Supreme Court ruled that a juvenile found to have violated a criminal statute is equivalent to a trial in criminal court. Hence, double jeopardy occurred in his case. In this decision, the Court also stated that jeopardy occurs when evidence is presented at the adjudication hearing. Consequently, a waiver occurring after this constitutes double jeopardy.
Schall v. Martin In 1977, Gregory Martin was arrested and charged with possession of a weapon, assault, and robbery. He, along with two other juveniles, had allegedly hit another juvenile on the head with a gun and stolen his jacket and sneakers ( U.S. Supreme Court cases, 1999). The court found that he was at serious risk to commit another crime, hence he was detained pending adjudication.
Schall v. Martin Martin s attorney filed a writ of habeas corpus, arguing that the detainment was unfair as it was essentially another punishment. The U.S. Supreme Court decided that preventive detention is constitutional as it serves a legitimate State objective in protecting both the juvenile and society from pretrial crime and is not intended to punish the juvenile ( U.S. Supreme Court cases, 1999, para. 25).
Stanford v. Kentucky Kevin Stanford, at age 17, was convicted of murder, sodomy, robbery, and receiving stolen property. He was sentenced to death under the Kentucky statute that allowed capital punishment for juveniles convicted of Class A felonies or capital crimes ( Stanford v. Kentucky, n.d.). Stanford appealed, arguing that capital punishment for an individual his age violated his constitutional rights. His case was consolidated with that of Wilkins v. Missouri. Wilkins was a 16 year old who was appealing his sentence of capital punishment for murder.
Stanford v. Kentucky In their decision, the U.S. Supreme Court examined the evolving standards of decency. They stated that there is not a national consensus regarding the use of capital punishment for 16 and 17 year olds because some states allowed it for those 16 and under, and others allowed it for those 17 and under ( Stanford v. Kentucky, n.d.). Consequently, the Court ruled that the age at which a juvenile is subjected to the death penalty should be decided by each state rather than the Court. Hence, the juvenile death penalty is not unconstitutional.
Roper v. Simmons In 2005, the U.S. Supreme Court would again be presented with a case involving the juvenile death penalty. In 1993, Christopher Simmons was sentenced to death for throwing a neighbor over a bridge to her death ( Roper v. Simmons, n.d.).
Roper v. Simmons The U.S. Supreme Court again held that the standards of decency are evolving to where society considers executing a juvenile to be cruel and unusual punishment. Justice Kennedy, who wrote for the majority, indicated research stating that juveniles lack adult maturity and a sense of responsibility. Additionally, the Court specified that there is overwhelming international opinion against juvenile execution.
References McKeiver v. Pennsylvania. (n.d.). Retrieved from https://www.oyez.org/cases/1970/322 National Juvenile Defender Center. (n.d.-a). In re Gault. Retrieved from http://njdc.info/practicepolicy-resources/united-states-supreme-court-juvenile-justice-jurisprudence/in-re-gault/ National Juvenile Defender Center. (n.d.-b). United States Supreme Court juvenile justice jurisprudence. Retrieved from http://njdc.info/practice-policy-resources/united-statessupreme-court-juvenile-justice-jurisprudence/ Roper v. Simmons. (n.d.). Retrieved from https://www.oyez.org/cases/2004/03-633 Stanford v. Kentucky. (n.d.). Retrieved from https://www.oyez.org/cases/1988/87-5765 United States Courts. (n.d.). Facts and case summary: In re Gault 387 U.S. 1 (1967). Retrieved from http://www.uscourts.gov/educational-resources/educational-activities/facts-and-casesummary-re-gault U.S. Supreme Court cases have had an impact on the character and procedures of the juvenile justice system. (1999, December). 1999 National Report Series, Juvenile Justice Bulletin: Juvenile Justice: A Century of Change. Retrieved from https://www.ncjrs.gov/html/ojjdp/9912_2/juv2.html