/JOO-vuh-nile dee-LIN-kwen-see pro-SEE-dings/·procedural term
Also known as:juvenile delinquency proceeding · juvenile court proceedings · delinquency case
Written by attorneys · grounded in primary & secondary sources — see below
A judicial proceeding in which a minor is adjudicated for conduct that would constitute a criminal offense if committed by an adult. The proceeding determines whether the juvenile committed the alleged acts and what disposition follows. Due process requires proof of every element beyond a reasonable doubt.
Sources & Authorities
How it applies
Common Examples
6
Burden of Proof Challenge
Javier Jimenez faces a juvenile delinquency petition alleging he intentionally sideswiped a cyclist during a road rage incident. At the adjudication hearing the judge announces that clear and convincing evidence will suffice because the matter is in juvenile court. Javier objects. The court must reject the lower standard and require the prosecution to prove every element beyond a reasonable doubt.
Right to Counsel Dispute
Jerome Jackson appears in juvenile court on a delinquency petition for alleged theft. No attorney has been appointed and the court proceeds directly to the adjudicatory hearing. Jerome requests counsel before any testimony begins. The court must appoint counsel because the proceeding can result in loss of liberty.
Select any source to read its text and confirm it supports the definition.
Cases
Course Outlines
In re Gault387 U.S. 1, 13, 87 S.Ct. 1428, 1436, 18 L.Ed.2d 527 (1967)
School Search Evidence
Jason Jung is charged in juvenile court with possession of contraband after a school official searched his backpack. The search occurred after a teacher reported suspicious behavior in the hallway. Jason moves to suppress the evidence. The court must evaluate whether the search satisfied the reasonableness standard applicable in the school setting.
New Jersey v. T.L.O.469 U.S. 325 (1985)
Public Hearing Request
James Johnson faces a juvenile delinquency adjudication for alleged assault. His family requests that the hearing be closed to the public. The court must decide whether closure is consistent with the constitutional requirement of an open proceeding.
In re Oliver333 U.S. 257, 273 (1948)
Element Allocation Dispute
Jillian James is adjudicated delinquent for manslaughter after the court placed the burden on her to disprove malice. The prosecution presented evidence of the killing but offered no proof of the required mental state. The court must reallocate the burden so that the state proves every element beyond a reasonable doubt.
Mullaney v. Wilbur421 U.S. 684, 95 S.Ct. 1881, 44 L.Ed.2d 508 (1975)
Prior Adjudication Issue
Justin Jarvis faces a new delinquency petition. The court considers his earlier juvenile adjudication as an element that increases the available disposition. Justin argues the prior finding cannot be used without a jury determination. The court must decide whether the prior adjudication may be treated as a sentencing factor.
Almendarez-Torres v. United States523 U.S. 224 (1998)
Common questions
Frequently Asked
4
What standard of proof applies in juvenile delinquency proceedings based on criminal acts?+
The Due Process Clause requires proof beyond a reasonable doubt of every element. This standard applies even though the proceeding is labeled civil or rehabilitative. A lower standard such as clear and convincing evidence or preponderance violates due process when the petition alleges conduct that would be criminal for an adult.
Supporting sources
Does the Constitution require jury trials in juvenile delinquency proceedings?+
No. The Sixth Amendment jury trial right does not extend to juvenile adjudications. The proceeding may be conducted before a judge alone without violating due process.
Supporting sources
When may evidence obtained in a school search be used in a juvenile delinquency proceeding?+
Evidence from a school search is admissible if the search was reasonable under the circumstances. School officials need not obtain a warrant or satisfy the probable cause standard required of police. The search must be justified at its inception and reasonably related in scope to the circumstances that prompted it.
Supporting sources
What due process protections attach to the adjudicatory stage of a juvenile delinquency proceeding?+
The juvenile is entitled to notice of the charges, the right to counsel, the opportunity to confront and cross-examine witnesses, and the privilege against self-incrimination. These protections apply because the proceeding can result in a loss of liberty.
Supporting sources
397 U.S. 358, 90 S. Ct. 1068, 25 L. Ed. 2d 368 (1970)Criminal Procedure
…than for ordinary civil litigation. II When one assesses the consequences of an erroneous factual determination in a juvenile delinquency proceeding in which a youth is accused of a crime, I think it must be concluded that, while the consequences are not identical to those in a criminal case, the differences will not support a…