Simone Lawson
In the case of Schall v. Martin, the U.S. Supreme Court ruled that holding a juvenile in a detention facility before a hearing does not violate the Constitution. This case addressed the constitutionality of preventative detention of juveniles, and the Court's decision set a precedent for the use of preventative detention as a measure in the juvenile justice system. While the specifics of the case may vary, the ruling in Schall v. Martin has had a significant impact on how juvenile offenders are treated within the legal framework.
| Characteristics | Values |
|---|---|
| Case name | In re Gault |
| Year | 1967 |
| Court | Supreme Court of Arizona, Supreme Court of the United States |
| Holding | The constitutional guarantee of due process applies to proceedings in which juveniles are charged as delinquents |
| Specifics | Juveniles must be afforded basic constitutional protections, such as advance notice of the charges, the right to counsel, the right to confront and cross-examine adverse witnesses, and the right to remain silent |
| Related cases | Kent v. United States, New Jersey v. T.L.O., Moss v. Weaver, United States v. Doe, McKeiver v. Pennsylvania, Oklahoma Publishing Company v. District Court, Smith v. Daily Mail Publishing Company, Eddings v. Oklahoma, Schall v. Martin, Breed v. Jones |
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What You'll Learn
In re Gault, 387 U.S. 1 (1967)
In the case of In re Gault, 387 U.S. 1 (1967), the United States Supreme Court addressed the constitutional rights of juveniles in the context of delinquency proceedings and due process. The case centred around 15-year-old Gerald ("Jerry") Gault, who was accused of making obscene telephone calls to a neighbour, Mrs. Cook, on June 8, 1964. As a result of the complaint filed by Mrs. Cook, Gault and his friend, Ronald Lewis, were arrested and taken to a juvenile detention home.
At the time of his arrest, Gault was already on probation for being involved in an incident where another boy stole a wallet from a woman's purse. Following the telephone call incident, Gault was taken into custody and hearings were held before a juvenile court judge. Subsequently, Gault was ordered to be committed to the State Industrial School as a juvenile delinquent until he reached the age of majority.
Gault's parents, particularly his mother, Mrs. Gault, played an active role in challenging their son's detention. They brought a habeas corpus action in the state courts, contesting the constitutionality of the Arizona Juvenile Code and the procedures employed in Gault's case. They argued that their son had been denied various procedural due process rights. However, the state courts, including the Arizona Supreme Court, affirmed the dismissal of the writ, upholding the constitutionality of the Arizona Juvenile Code and the commitment procedure.
The Supreme Court of Arizona acknowledged that Mrs. Gault was aware of her rights, including the right to counsel, to subpoena and cross-examine witnesses, and to confront the witnesses against her son. Nonetheless, the Supreme Court of the United States reversed the lower court's decision and emphasised the importance of due process. They asserted that due process is the "primary and indispensable foundation of individual freedom" and that procedural rules derived from due process are essential for evaluating facts and resolving conflicts.
The case of In re Gault, therefore, underscores the extension of constitutional protections to juveniles in delinquency proceedings. While juveniles may not receive the full range of rights afforded to adult criminal defendants, the case highlights the necessity of fundamental procedural safeguards, such as the right to counsel, notice of charges, and confrontation of witnesses, to ensure fair treatment for juveniles within the justice system.
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Juvenile courts and the right to trial by jury
Juveniles are not entitled to the same full range of rights as adult criminal defendants. In the US, the Sixth Amendment right to a jury trial is considered a fundamental part of a fair trial in adult criminal proceedings. However, in juvenile delinquency proceedings, this right does not extend to minors. The US Supreme Court has ruled that juvenile court proceedings are not "criminal prosecutions" within the meaning and reach of the Sixth Amendment. Instead, the Court views these proceedings as rehabilitative in nature.
In the 1971 case of McKeiver v. Pennsylvania, the US Supreme Court held that juveniles do not have the right to a jury trial in delinquency proceedings. The Court's decision centred on fundamental fairness and the need for accurate fact-finding in a case. The justices expressed concern that requiring jury trials would make juvenile proceedings “fully adversary” and destroy the "idealistic prospect of an intimate, informal protective proceeding". They also questioned whether jury trials would significantly improve the ability of courts to determine case facts.
Despite the Supreme Court's ruling, some states have chosen to offer jury trials in juvenile court under certain circumstances. For example, a few states provide this right when the potential sentence is particularly severe. Additionally, ten states, including Alaska, Kansas, and Massachusetts, have determined that juveniles possess a constitutional right to a jury trial during delinquency proceedings.
The exclusion of jury trials in juvenile courts is part of a broader pattern of limited constitutional rights afforded to juveniles. Historically, very few constitutional rights applied in these courts. While this has changed over time, with the US Supreme Court extending certain due process rights to juveniles, the right to trial by jury remains absent in most jurisdictions.
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Juvenile justice system and procedural parameters
The juvenile justice system in the United States was established about a century ago, with the first juvenile court being set up in Cook County, Illinois, in 1899. The juvenile justice system is distinct from the adult criminal justice system, as it focuses on rehabilitation and addressing the individual needs of the child or adolescent. The juvenile justice system has evolved over time, with a shift towards more procedural formality and the extension of constitutional rights to juveniles.
In the case of In re Gault (1967), the US Supreme Court held that juveniles in commitment proceedings must be afforded basic constitutional protections, such as advance notice of the charges, the right to counsel, the right to confront and cross-examine adverse witnesses, and the right to remain silent. This case brought to light the lack of formal process and constitutional due process in the juvenile justice system, and it extended the procedural safeguards required in juvenile court. The Supreme Court has also extended Fourth Amendment protections to juveniles, including the right to a probable cause hearing if arrested without a warrant.
However, the juvenile justice system has been criticised for lacking procedural parameters, leading to arbitrariness and a failure to provide the intended rehabilitative function. The practice of preventive detention of juveniles, which began in 1899, has raised constitutional concerns regarding the fundamental rights to liberty and due process. The equal protection clause, which requires that the law be applied equally to all people, is violated by the juvenile system's preventive detention rule. Additionally, the right to release on bail, which underscores the presumption of innocence, is denied to children in the juvenile justice system.
While the juvenile justice system aims to protect youthful offenders from the destructive punishments of criminal courts, there have been shifts in policy that have resulted in tougher consequences and the deprivation of the system's protections. In the late 1980s and early 1990s, an increase in juvenile crime rates led legislators to adopt "tough on crime" policies, exposing youth to harsh penalties and incarceration with adult offenders. Although juvenile crime rates have decreased since the 1990s, the harsh penalties remain in many state laws.
Today, the juvenile justice system maintains rehabilitation as its primary goal and continues to distinguish itself from the criminal justice system. Delinquency is generally defined as the commission of a criminal act by an individual under the age of 18, and youth may remain under the supervision of the juvenile court until age 21. Juvenile court judges have a range of legal options to balance public safety and the treatment needs of the youth, but there are concerns about the conditions in juvenile correctional facilities that resemble adult prisons.
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Constitutional protections for juveniles
Juveniles charged with crimes have a narrower range of rights than adults; they do not enjoy the full panoply of rights that adult criminal defendants are accorded. This is because the juvenile justice system is less punitive, so the consequences of being found delinquent are far less severe than the consequences of a conviction in adult court.
Historically, very few constitutional rights applied in juvenile courts, but this has started to change. In the 1960s and 1970s, the Supreme Court issued rulings that awarded juveniles some of the same due process rights as adults.
Juveniles have the same constitutional rights as adults regarding freedom from unreasonable searches and seizures. The Supreme Court has extended the search and seizure protections of the Fourth Amendment to juveniles. It has also been held that the Fourth Amendment requires that a juvenile arrested without a warrant be provided a probable cause hearing. The exclusionary rule also applies to juvenile delinquency adjudications.
Juveniles have a constitutional right to confront and cross-examine witnesses. Their attorney can challenge the testimony provided by prosecution witnesses. The Fifth Amendment protects an individual from self-incrimination, and this right extends to juveniles, who cannot be required to provide testimony against themselves. According to the U.S. Supreme Court, a juvenile has a constitutional right to notice of the charges against them, and they also have a right to an attorney, including a right to a public defender if they cannot afford one.
Juveniles do not have a right to a jury trial in juvenile court as it is believed that this would undermine the confidentiality of juvenile court proceedings. Juvenile courts are supposed to rehabilitate rather than punish a juvenile, and a formal adversarial process might hinder that goal.
In the case of In re Gault, 387 U.S. 1, 87 S. Ct. 1428, 18 L. Ed. 2d 527 (1967), the Supreme Court of Arizona found that the parents of Gerald Gault knew of their right to counsel, to subpoena and cross-examine witnesses, of the right to confront the witnesses against Gerald, and the possible consequences of a finding of delinquency. The parents also knew the exact nature of the charge against Gerald from the day he was taken into custody.
In the case of Kent v. United States, 383 U.S. 541, 383 U.S. 562 (1966), it was held that hearings must measure up to the essentials of due process and fair treatment. This view was reiterated in connection with a juvenile court adjudication of "delinquency," as a requirement of the Due Process Clause of the Fourteenth Amendment.
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Supreme Court rulings on juvenile offenders
The US Supreme Court has ruled that juveniles must be afforded basic constitutional protections in juvenile commitment proceedings. These protections include advance notice of charges, the right to counsel, the right to confront and cross-examine adverse witnesses, and the right to remain silent. This was established in the 1967 case of In re Gault, where the Supreme Court of Arizona found that the parents of Gerald Gault were aware of their right to counsel, to subpoena and cross-examine witnesses, and to confront the witnesses against Gerald.
The Supreme Court has also extended the search and seizure protections of the Fourth Amendment to juveniles, as seen in New Jersey v. T.L.O. in 1985. Additionally, the Fourth Amendment requires that a juvenile arrested without a warrant be provided with a probable cause hearing, as per Moss v. Weaver in 1976.
In terms of sentencing, the Supreme Court has made significant rulings regarding the treatment of juvenile offenders. In 2005, the Court held in Roper v. Simmons that imposing the death penalty on an individual who was under eighteen at the time of the crime was cruel and unusual punishment under the Eighth Amendment. The Court acknowledged the differences between children and adults, including their lack of maturity and underdeveloped sense of responsibility, which diminish a child's culpability.
Building on Roper, the Court in Graham v. Florida (2010) ruled that sentencing a juvenile to life without the possibility of parole for a non-homicidal crime violates the Eighth Amendment. This ruling requires states to give juveniles a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation."
In Miller v. Alabama (2012), the Court held that it is unconstitutional to impose a sentence of life without parole on a child unless they are the rare juvenile offender who exhibits such irretrievable depravity that rehabilitation is impossible. This ruling applies retroactively, as it establishes a substantive rule of constitutional law.
These cases have significantly shaped juvenile justice in the United States, altering the sentencing of juvenile offenders and ensuring that their constitutional rights are protected during commitment proceedings.
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Frequently asked questions
Schall v. Martin held that it was not a constitutional violation to hold a juvenile in a detention facility before a hearing.
The case concerned a newspaper obtaining the name and photograph of a juvenile involved in a juvenile court proceeding.
The U.S. Supreme Court found that it was an unconstitutional restriction on the press to prevent publication of that information, even though the juvenile had a right to confidentiality in such proceedings.
Some other important cases include Kent v. United States, Eddings v. Oklahoma, McKeiver v. Pennsylvania, and In re Gault.
The Supreme Court held that juveniles must be afforded basic constitutional protections in juvenile commitment proceedings, such as advance notice of the charges, the right to counsel, the right to confront and cross-examine adverse witnesses, and the right to remain silent.
