Federal Caselaw

Application of Gault 387 U.S. 1, 87 S.Ct. 1428 (1967)

Nature of the case: Proceeding on appeal from a judgment of the Supreme Court of Arizona, 99 Ariz. 181, 407 P.2d 760, affirming dismissal of petition for writ of habeas corpus filed by parents to secure release of their 15-year-old son who had been committed as juvenile delinquent to state industrial school. The United States Supreme Court, Mr. Justice Fortas, held that juvenile has right to notice of charges, to counsel, to confrontation and cross-examination of witnesses, and to privilege against self-incrimination. Judgment reversed and cause remanded with directions. Mr. Justice Harlan dissented in part; Mr. Justice Stewart dissented.

In re Winship 397 U.S. 358, 90 S.Ct. 1068 (1970)

Nature of the case: Juvenile delinquency proceeding. The Family Court, BronxCounty, adjudged the infant to be a juvenile delinquent, and he appealed. The Supreme Court, Appellate Division, affirmed, 30 A.D.2d 781, 291 N.Y.S.2d 1005. The infant appealed to the Court of Appeals on constitutional grounds, and the order was again affirmed, 24 N.Y.2d 196, 299 N.Y.S.2d 414, 247 N.E.2d 253. Probable jurisdiction was noted. The Supreme Court, Mr. Justice Brennan, held that the reasonable-doubt standard of criminal law has constitutional stature and that juveniles, like adults, are constitutionally entitled to proof beyond reasonable doubt when they are charged with a violation of a criminal law. Reversed. Mr. Chief Justice Burger, Mr. Justice Stewart and Mr. Justice Black dissented.

McKeiver v. Pennsylvania 403 U.S. 528, 91 S.Ct. 1976 (1971)

Nature of the case: The Supreme Court, Mr. Justice Blackmun announced the court's judgments and delivered an opinion determining that trial by jury in adjudicative stage of state juvenile court delinquency proceeding is not constitutionally required. Affirmed. Mr. Justice Harlan concurred in the judgments and filed opinion. Mr. Justice White concurred and filed opinion. Mr. Justice Brennan concurred in the judgment in No. 322 and dissented in No. 128 and filed opinion. Mr. Justice Douglas, with whom Mr. Justice Black and Mr. Justice Marshall concurred dissented and filed opinion. 


United States v. R.L.C. 503 U.S. 291, 112 S.Ct. 1329 (1992)

Nature of the case: Juvenile was found to be delinquent by the United States District Court for the District of Minnesota, Harry H. McLaughlin, J., for conduct constituting involuntary manslaughter. Juvenile appealed. The Court of Appeals for the Eighth Circuit, 915 F.2d 320, vacated and remanded. Juvenile was resentenced and Government petitioned for writ of certiorari. The Supreme Court, Justice Souter, delivering the opinion of the Court as to Parts I, II-A and III, held that maximum sentence which could be imposed was maximum sentence that could be imposed if juvenile were being sentenced after application of United States Sentencing Guidelines, and, in opinion with respect to Parts II-B and II-C, joined by Chief Justice Rehnquist and Justices White and Stevens, held that if any ambiguity about a sentencing statute's intended scope survives after analysis of its legislative history, construction yielding shorter sentence would be chosen under rule of lenity. Court of Appeals affirmed. Justice Scalia, with whom Justices Kennedy and Thomas joined, issued opinion concurring in part and concurring in judgment. Justice Thomas issued opinion concurring in part and concurring in judgment. Justice O'Connor, with whom Justice Blackmun joined, issued dissenting opinion

Reno v. Flores, 507 U.S. 292, 113 S. Ct. 1439, 123 L. Ed. 2d 1 (1993)

Nature of the case: A class of juvenile aliens, who had been detained on suspicion of being deportable, brought suit challenging Immigration and Naturalization Service (INS) regulation governing release of detained alien juveniles. The Supreme Court, Justice Scalia, held that: (1) regulation permitting detained juvenile aliens to be released only to their parents, close relatives, or legal guardians, except in unusual and compelling circumstances, does not facially violate substantive due process; (2) INS procedures do not deny juvenile aliens procedural due process; and (3) regulation is within scope of Attorney General's statutory discretion to continue custody over arrested aliens.

Graham v. Florida 130 S.Ct. 2011, 176 L.Ed.2d 825 (2010)

Nature of the case: Background: The State of Florida filed a probation violation report against defendant, who was on probation for crimes he had committed while a juvenile. The Circuit Court, DuvalCounty, Lance M. Day, J., determined that a probation violation occurred and sentenced defendant to life imprisonment without the possibility of parole. Defendant appealed. The District Court of Appeal of Florida, First District, Wolf, J., 982 So.2d 43, affirmed and the Supreme Court of Florida, 2008 WL 3896182, denied review. Certiorari was granted. Holdings: The Supreme Court, Justice Kennedy, held that: (1) Eighth Amendment prohibits imposition of life without parole sentence on juvenile offender who did not commit homicide, and (2) State must give juvenile nonhomicide offender sentenced to life without parole meaningful opportunity to obtain release. Reversed and remanded.

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