421 U.S. 519 (1975) |
SCOTUS decided 1975-05-27
The Court found that double jeopardy applies to an individual who is tried as a juvenile and is then later tried as an adult.Result: Win
The case is important because, similar to other Court precedents in the context of juvenile court, the Court sees juvenile court as similar to adult criminal court. While the mission of juvenile court has some differences – such as more emphasis on rehabilitation – the Court acknowledges that there are many similarities between juvenile proceedings and adult criminal trials.
Law type: Criminal
Topic(s): Double jeopardy and Juvenile defendants
State of origin: CA
Robert L. Walker argued the cause for respondent. With him on the brief was Peter Bull. (National Center for Youth Law)
Others involved: Briefs of amici curiae urging affirmance were filed by Alfred L. Scanlan for the National Council of Juvenile Court Judges; by David Gilman for the National Council on Crime and Delinquency et al.; and by Richard S. Buckley and Laurance S. Smith for the California Public Defenders Assn.
Organization role: Sponsor
Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
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CASE DETAILS(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
The prosecution of respondent as an adult in California Superior Court, after an adjudicatory finding in Juvenile Court that he had violated a criminal statute and a subsequent finding that he was unfit for treatment as a juvenile, violated the Double Jeopardy Clause of the Fifth Amendment, as applied to the States through the Fourteenth Amendment. Pp. 421 U. S. 528-541.
(a) Respondent was put in jeopardy at the Juvenile Court adjudicatory hearing, whose object was to determine whether he had committed acts that violated a criminal law and whose potential consequences included both the stigma inherent in that determination and the deprivation of liberty for many years. Jeopardy attached when the Juvenile Court, as the trier of the facts, began to hear evidence. Pp. 421 U. S. 528-531.
(b) Contrary to petitioner’s contention, respondent’s trial in Superior Court for the same offense as that for which he had been tried in Juvenile Court, violated the policies of the Double Jeopardy Clause, even if respondent “never faced the risk of more than one punishment,” since the Clause “is written in terms of potential or risk of trial and conviction, not punishment.” Price v. Georgia, 398 U. S. 323, 398 U. S. 329. Respondent was subjected to the burden of two trials for the same offense; he was twice put to the task of marshaling his resources against those of the State, twice subjected to the “heavy personal strain” that such an experience represents. Pp. 421 U. S. 532-533.
(c) If there is to be an exception to the constitutional protection against a second trial in the context of the juvenile court system, it must be justified by interests of society, reflected in that unique institution, or of juveniles themselves, of sufficient substance to render tolerable the costs and burdens that the exception will entail in individual cases. Pp. 421 U. S. 533-534.
(d) Giving respondent the constitutional protection against multiple trials in this context will not, as petitioner claims, diminish the flexibility and informality of juvenile court proceedings
Page 421 U. S. 520
to the extent that those qualities relate uniquely to the goals of the juvenile court system. A requirement that transfer hearings be held prior to adjudicatory hearings does not alter the nature of the latter proceedings. More significantly, such a requirement need not affect the quality of decisionmaking at transfer hearings themselves. The burdens petitioner envisions would not pose a significant problem for the administration of the juvenile court system, and, quite apart from that consideration, transfer hearings prior to adjudication will aid the objectives of that system. Pp. 421 U. S. 535-541.
497 F.2d 1160, vacated and remanded.