Also known as: juvenile offenders · juvenile delinquent · minor offender
Written by attorneys · grounded in primary & secondary sources — see below
A person under the age of eighteen who commits a criminal offense. Such offenders receive categorical Eighth Amendment protections that bar the death penalty in all cases and life imprisonment without parole for non-homicide crimes.
Jonathan Jaffe, age sixteen, repeatedly contaminated food orders at a fast-food restaurant as a prank, causing hundreds of customers to become ill but no deaths. After conviction on multiple felonies, the court imposed life imprisonment without parole. The sentence violates the Eighth Amendment because Jonathan was a juvenile at the time of the non-homicide offenses.
Joy Jiang, age seventeen, fatally shot a classmate after weeks of planning documented in notes and social media posts. Prosecutors sought the death penalty upon conviction for capital murder. The Eighth Amendment forbids execution because Joy was under eighteen at the time of the offense.
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Jorge Juarez, age fifteen, faced delinquency proceedings after allegedly taking property from a store. The court applied the beyond-a-reasonable-doubt standard to each element of the charged conduct. This standard protects the juvenile offender by ensuring the same level of certainty required in adult criminal trials.
James Johnson, age seventeen, killed a coworker during a workplace dispute and received a mandatory life-without-parole sentence under state law. The court must instead consider the offender's youth and individual circumstances before imposing such a penalty.
Joanna Jung, age seventeen, engaged in sexual conduct with a younger partner. The statute imposed criminal liability only on males in her position. The distinction survives equal-protection review because it addresses the risk of teenage pregnancy that applies only to female victims.
Jeanette Jensen, age seventeen with documented severe developmental delays, set a fire that caused a death. The court barred the death penalty because her intellectual disability independently rendered her ineligible for capital punishment.
Yes. The Eighth Amendment categorically prohibits sentencing a juvenile offender to life imprisonment without the possibility of parole when the crime is a non-homicide offense. The rule applies regardless of the seriousness of the conduct or the degree of planning involved.
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No. The Eighth Amendment categorically bars the death penalty for any offender who was under eighteen years of age at the time of the capital crime. The prohibition is absolute and does not depend on the level of premeditation or the severity of the offense.
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Yes. The Due Process Clause requires proof beyond a reasonable doubt of every element of the charged offense before a juvenile can be adjudicated delinquent and committed to a state institution.
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…an act which would constitute a crime if committed by an adult.[^maj-1] Section 712 of the New York Family Court Act defines a juvenile delinquent as "a person over seven and less than sixteen years of age who does any act which, if done by an adult, would constitute a crime." During a 1967 adjudicatory hearing, conducted pursuant to…