In re Winship

Supreme Court of the United States · 1970 · Criminal Law

Criminal LawJuvenile DelinquencyDue ProcessBurden of Proofreasonable doubtdue processjuvenile courtdelinquency adjudication

Facts

New York law defined a juvenile delinquent as a person between seven and sixteen who commits an act that would be a crime if committed by an adult. At an adjudicatory hearing, a Family Court judge found that 12-year-old Winship had entered a locker and stolen $112 from a woman's pocketbook, an act alleged to constitute larceny if done by an adult. The judge acknowledged that the proof might not establish guilt beyond a reasonable doubt but applied the statutory preponderance standard instead. Afterward, Winship was ordered placed in a training school for an initial 18-month period, subject to annual extensions until age eighteen.

Issue

Does the Due Process Clause require proof beyond a reasonable doubt during the adjudicatory stage of a juvenile delinquency proceeding when the juvenile is charged with conduct that would be a crime if committed by an adult? More specifically, may a state constitutionally use a mere preponderance standard for that determination?

Rule

The Due Process Clause protects an accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged. That constitutional safeguard applies equally at the adjudicatory stage of a juvenile delinquency proceeding when the charged act would constitute a crime if committed by an adult.

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In Cleveland, 15-year-old Mateo Ruiz is charged in juvenile court with conduct that would be robbery if committed by an adult. At the adjudicatory hearing, the judge finds it more likely than not that Mateo took the wallet and enters a delinquency finding under a state statute requiring proof by a preponderance of the evidence. Mateo may be committed to a state youth facility for up to three years.

If Mateo challenges the adjudication on due process grounds, what is the strongest argument?

Explanation. The governing rule is that the Due Process Clause protects against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged, and that safeguard applies at the adjudicatory stage of a juvenile delinquency proceeding when the charged act would be criminal if committed by an adult. The civil label of juvenile court does not remove that protection, especially where the juvenile faces stigma and loss of liberty.