Kent v. United States

Following is the case brief for Kent v. United States, 383 U.S. 541 (1966)

Case Summary of Kent v. United States:

  • Morris Kent, at age 16, committed several serious crimes.
  • The Juvenile Court, without providing Kent’s counsel with important files or allowing a hearing on the issue, decided to waive jurisdiction so Kent could be tried as an adult.
  • Kent’s objections to the waiver were denied.
  • Kent was ultimately tried as an adult and sentenced to 30 to 90 years in prison.
  • The D.C. Circuit Court of Appeals affirmed the conviction and found the Juvenile Court’s waiver to be valid.
  • The U.S. Supreme Court reversed and remanded.  The Court held that due process and basic fairness were not satisfied by the Juvenile Court’s waiver decision, and that the Juvenile Court did not do the “full investigation” required by law before deciding waiver.

Kent v. United States Case Brief

Statement of the Facts:

Morris Kent, when he was 16-years-old, was arrested for burglary, robbery, and rape.  Given that he was a juvenile, he was subject to the exclusive jurisdiction of the Juvenile Court.  But, the Juvenile Court could waive jurisdiction and have a juvenile tried as an adult after doing a “full investigation” with regard to waiver.

Kent’s attorney moved the Juvenile Court for a hearing on waiver, and moved for Kent’s Social Service file, which had information on Kent for a prior offense.  The Juvenile Court ignored those motions, and entered the waiver order, stating that it had conducted a “full investigation.”

Prosecutors then indicted Kent as an adult.  Kent’s attorney moved to dismiss the indictment, arguing that the Juvenile Court waiver was invalid.  The District Court denied the motion, and Kent was tried, convicted, sentenced to 30 to 90 years imprisonment.  (He was found not guilty by reason of insanity with regard to the charge of rape).

Procedural History:

  • Following Kent’s sentencing, he appealed the waiver issue among other issues to the D.C. Circuit Court of Appeals.
  • The D.C. Circuit Court of Appeals denied Kent relief, finding that the waiver procedure and order were valid.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Was the Juvenile Court’s procedure in waiving jurisdiction valid when it did not give the defendant’s counsel a hearing or access to the defendant’s file?  No.

Judgment:

The decision of the D.C. Circuit Court of Appeals is reversed and remanded.

Rule of Law or Legal Principle Applied:

Due process and fairness require that a juvenile should have access to relevant information and a hearing before a Juvenile Court can waive jurisdiction because such waiver is a “critically important” action.

Reasoning:

While there were many deficiencies with the way the D.C. police and juvenile system treated Kent throughout the process, the Court focused on the Juvenile Court’s decision to waive jurisdiction so Kent could be tried as an adult.

In this case, the Juvenile Court’s waiver order was invalid because it did not provide Kent’s counsel with the Social Service file, it did not allow Kent to have a hearing on waiver, it did not provide any stated reasons for its decision, and it does not seem to have conducted the “full investigation” required by statute.

A Juvenile Court has latitude in making the waiver determination, but that latitude is not complete.  The fact that the Juvenile Court stands in a parental, rather than criminal adversarial, role with regard to a juvenile does not mean that the Juvenile Court can make arbitrary decisions.  Here, due process and fairness mandate that the Juvenile Court follow some procedure, and that the statutory requirement of “full investigation,” has meaning.  A hearing, so the juvenile may challenge certain evidence and make arguments, is part of that investigation.

Moreover, the difference between juvenile adjudication and being tried as an adult is significant.  For Kent, it means the difference between treatment for five years, or the possibility of a death sentence.  Therefore, the waiver decision is “critically important,” and deserves due process and a full investigation.  That means a hearing, access to information, and a statement of reasons for the Juvenile Court’s decision.

Because Kent was 21 at the time of the Court’s decision, and therefore outside the reach of the Juvenile Court’s jurisdiction, the Court remanded the case to the District Court for a new hearing on whether the waiver was appropriate.  If it was not appropriate, Kent’s conviction must be vacated.

Concurring and Dissenting Opinions:

Concurring Opinion (Stewart):

Two decisions by the D.C. Circuit Court of Appeals were made after its decision in this case.  The judgment here should be vacated and remanded to the Court of Appeals to reconsider the issue in light of its subsequent decisions.

Significance:

Kent v. United States is a landmark decision because it stands for providing fundamental due process for juveniles.  As Justice Fortas stated in the Court’s opinion, sometimes juveniles get the worst of both worlds.  They are not given the procedural rules given to adult criminals, yet the juvenile system is unable to provide the kind of care and rehabilitation they should receive as young people deserving of rehabilitation.  Kent states that juveniles deserve due process and basic fairness.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

Campaign for Youth Justice Commemorating 51st Anniversary of the Decision

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