| Court: |
US Supreme Court |
|
| Facts: |
Defendant, 12 years old, is charged with theft of $112 from a woman's pocketbook
in a locker. If an adult committed this act, it would be the crime of
"larceny," so it became necessary to decide whether the defendant is therefore
a delinquent. The judge ruled, in keeping with §744(b) of NY Family
Court Act, that the determination must be based on a "preponderance of the
evidence." This resulted in potentially six years of commitment (i.e., until
he turned 18) in a "training school;" at least 18 months. |
|
| Posture: |
Adjudicatory hearing (in NY Family Court?) ruled that "preponderance of the evidence"
was a sufficient standard for classification as "Delinquent" and that "beyond
reasonable doubt" was not required. Defendant appealed, Appellate division of NY
Supreme Court (the intermediate level) affirmed without comment. New York Court
of appeals affirmed as well. |
|
| Issue: |
Whether proof beyond reasonable doubt is ne of the essentials of due process and
fair treatment required during the adjudicatory stage when a juvenile is
charged with an act that would be a crime if committed by an adult. |
|
| Holding: |
The Due Process clause protects against conviction except upon proof beyond
reasonable doubt of every element. This applies at the adjudicatory
stage. Reversed. |
|
| Rule: |
The constitution guaranteed due process (6th and 14th) |
|
| Reasoning: |
Various strategies
- History (i.e., "dates from early years as a nation"), it's accepted as the
common law standard.
- Lots of prior decisions as well: Brinegar v. United States and
Speiser v Randall. Protects against fact-finding error.
- Would otherwise erode the moral authority of the criminal law.
- The process isn't error-free, so the high standard minimizes error
|
|
| Dicta: |
Concurring opinion stresses balance of social utility (wrongful conviction
is worse than wrongful acquittal) |