Breed v. Jones

Following is the case brief for Breed v. Jones, 421 U.S. 519 (1975)

Case Summary of Breed v. Jones:

  • A 17-year-old was adjudicated delinquent in juvenile court, and then later tried as an adult in criminal court for the same robbery offense.
  • The 17-year-old Respondent’s petition for habeas relief was denied in State court prior to his adult criminal trial.  However, he sought habeas relief again in federal court following his conviction for robbery.
  • The Ninth Circuit Court of Appeals held that the second adult criminal trial violated the Double Jeopardy Clause.
  • The U.S. Supreme Court agreed, holding that a trial in adult criminal court, following adjudication in juvenile court for the same offense, violated the Double Jeopardy Clause.

Breed v. Jones Case Brief

Statement of the Facts:

17-year-old Respondent Jones was adjudicated in Juvenile Court to have committed acts that would constitute robbery if tried as an adult.  After the Juvenile Court hearing, the court determined that Jones should be tried as an adult.  Jones filed a writ of habeas corpus, claiming that the adult criminal trial put him in double jeopardy in violation of the Fifth and Fourteenth Amendments.

Procedural History:

  • The state trial court, the court of appeal, and the California Supreme Court denied the writ.
  • Jones was tried as an adult and found guilty of first-degree robbery.
  • Jones filed another writ of habeas corpus in federal court, again raising the issue of double jeopardy.
  • The District Court denied the writ, finding that juvenile and adult criminal proceedings are different.
  • The Ninth Circuit Court of Appeals reversed, finding double jeopardy applicable to juvenile proceedings.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does a trial in adult criminal court following an adjudication in juvenile court for the same offense constitute a violation of the Double Jeopardy Clause?  Yes.

Judgment:

The criminal conviction against Jones is vacated, and the case is remanded to the Ninth Circuit Court of Appeals for further proceedings consistent with the Court’s decision.

Rule of Law or Legal Principle Applied:

Trying someone in adult criminal court after having adjudicated them delinquent in juvenile court for the same offense is a violation of the Double Jeopardy Clause.

Reasoning:

A juvenile court proceeding is the same as an adult criminal court proceeding in many respects.  The object of a juvenile proceeding is to determine criminal guilt, and it results in a stigma of having committed a crime as well as the possible deprivation of liberty for many years.

Thus, jeopardy attaches when a juvenile court, as a trier of fact, begins to hear evidence.  Further, the double jeopardy violation is clear when Jones was subjected to two trials for the same offense, was twice forced to defend against charges filed by the State, and was twice forced to deal with the personal strain of being tried for a crime.

There is an easy, and constitutional, way to avoid a double jeopardy problem in this type of case.  That is to take advantage of the transfer provisions that already exist in juvenile laws, which permit a juvenile to be transferred to adult court for a serious crime before any trial is initiated.

Significance:

Breed v. Jones is significant because, similar to other Court precedents in the juvenile court context, the Court is willing to view juvenile court as similar to adult criminal court.  While juvenile court has some difference in mission – an increased emphasis on rehabilitation, for example – the Court acknowledges that there are many similarities between juvenile proceedings and adult criminal trials.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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