McKeiver v. Pennsylvania

Following is the case brief for McKeiver v. Pennsylvania, 403 U.S. 528 (1971)

Case Summary of McKeiver v. Pennsylvania:

  • A number of juveniles in Pennsylvania and North Carolina were adjudicated delinquent on charges that would be criminal offenses if committed by an adult.  The courts in all of the cases denied the juveniles a jury trial.
  • The Supreme Courts of Pennsylvania and North Carolina affirmed the denial of the jury trials in juvenile court.
  • The U.S. Supreme Court affirmed, finding that due process does not require jury trials for juvenile courts.

McKeiver v. Pennsylvania Case Brief

Statement of the Facts:

This case is the consolidation of several cases from Pennsylvania and North Carolina.  In the Pennsylvania cases one of the appellants, a 15 year old, was charged with robbery, larceny, and receiving stolen goods; the other, a 16 year old, was charged with assault on a police officer.  In the North Carolina cases, students ranging in age from 11 to 15 were charged with disorderly conduct and other offenses in connection with protests involving racial discrimination.

In all of the cases, those charged were juveniles and were all denied a jury trial in juvenile court.  In the North Carolina cases specifically, the juveniles were tried in proceedings that were not open to the public.  All juveniles appealed the denial of their requests for jury trials.

Procedural History:

  • In Pennsylvania, the State Supreme Court found no constitutional right to a jury trial in juvenile court.
  • In North Carolina, the State Court of Appeals affirmed the denial of the appellants’ jury trials as did the Supreme Court of North Carolina.
  • The U.S. Supreme Court granted certiorari for the cases from both States.

Issue and Holding:

Does the Due Process Clause of the Fourteenth Amendment guarantee a right to a jury trial in juvenile court?  No.

Judgment:

The decisions of the Supreme Courts of Pennsylvania and North Carolina are affirmed.

Rule of Law or Legal Principle Applied:

A jury trial is not constitutionally required in juvenile court.

Reasoning:

The overriding due process standard for juvenile proceedings is fundamental fairness, per In re Gault, 387 U.S. 1, and In re Winship, 397 U.S. 358.  Those cases emphasized fairness in fact-finding procedures, including the right to counsel and right to cross-examination.  A jury is not essential to fairness in fact finding.  A juvenile prosecution is not considered civil or criminal.  Thus, the entirety of the Sixth Amendment does not necessarily apply, and jury trials are not required in juvenile cases.  In that vein, most States do not require jury trials in juvenile cases.

The juvenile courts, with their many shortcomings, have not lived up to their promise of focusing on rehabilitation and the paternal attention juveniles should receive.  Yet, it is not time to give up on juvenile courts and simply treat juveniles as we do adults in criminal court.

Concurring and Dissenting Opinions:

Concurring Opinion (White):

The States are not required, under due process, to have jury trials in juvenile court.  Unlike adult criminals who we view as making conscious choices and are responsible for their acts, the juvenile system rests on the assumption that juveniles act based on environmental forces not quite in their control.  The differences between criminal and juvenile court justify only requiring a jury trial in criminal cases.  States may still use juries if they so choose, but the Due Process Clause does not require it.

Concurring in part, Dissenting in part (Brennan):

The Pennsylvania cases were decided properly by the majority.  A jury trial is not required in juvenile courts, particularly when the general public is permitted to attend juvenile proceedings.  The North Carolina cases should be reversed, however, because those proceedings were not open to the public.  Thus, there is no check on the government by the community at large.

Concurring Opinion (Harlan):

Criminal jury trials should not be constitutionally required of the States, either under the Sixth Amendment or due process.  Therefore, the same would hold for juvenile courts as well.

Dissenting Opinion (Douglas):

The juveniles in these cases were charged with what would otherwise be crimes punishable by imprisonment if committed by adults.  Further, judges and law enforcement officers often incorrectly treat juveniles not as delinquents but as criminals.  We should, therefore, provide jury trials for the juveniles in these cases to ensure that they are not prejudged by a single juvenile court judge.

Significance:

McKeiver v. Pennsylvania is significant because it held on to the notion that juvenile courts are fundamentally different in approach and purpose than their criminal court counterparts.  Thus, that difference argues against using jury trials in juvenile court.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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