Supreme Court of Arizona, En Banc · 1985 · Family Law
Family LawJuvenile DelinquencyCapacityInfancy Defensejuvenile courtdelinquencycapacitywrongfulness
Facts
The petitioner, age thirteen, was arrested and charged in juvenile court with delinquency for alleged acts of sexual abuse and sexual conduct with a minor. During trial review he denied the allegations and, through counsel, requested a capacity hearing under A.R.S. § 13-501. The State opposed the request, arguing that the criminal code provision did not apply in juvenile delinquency proceedings. The juvenile court agreed with the State and denied application of the statute.
Issue
Whether A.R.S. § 13-501, which provides that a person under fourteen is not criminally responsible absent clear proof that the person knew the conduct was wrong, applies to delinquency proceedings in juvenile court.
Rule
A.R.S. § 13-501's criminal-code incapacity provision does not apply to juvenile delinquency proceedings. The juvenile code establishes a separate and distinct statutory scheme for handling children who commit acts that would be criminal if committed by adults, and the legislature intended juvenile proceedings to be governed by the juvenile code's own provisions rather than by § 13-501.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, 13-year-old Mateo Cruz is charged by petition in juvenile court with delinquency based on conduct that would amount to arson if committed by an adult. Mateo asks the judge to require the State to prove under A.R.S. § 13-501 that he knew his conduct was wrong before the adjudication may proceed.
How should the juvenile court rule?
Explanation. The majority held that A.R.S. § 13-501, a criminal-code incapacity provision, is inapplicable in juvenile delinquency proceedings. Even though a delinquent act is defined by reference to conduct that would be criminal if committed by an adult, the juvenile code is a separate statutory scheme with its own standards and provisions. Therefore the juvenile court should not import § 13-501 into the delinquency adjudication.