At age twelve, Samuel Winship was arrested and charged as a juvenile delinquent for breaking into a woman's locker and stealing $112 from her pocketbook. The charge also alleged that had Winship's act been done by an adult, it would constitute larceny. Relying on Section 744(b) of the New York Family Court Act, which provided that determinations of juvenile's guilt be based on a preponderance of the evidence, a Family Court found Winship guilty, despite acknowledging that the evidence did not establish his guilt beyond a reasonable doubt. Winship's appeal of the court's use of the lower "preponderance of the evidence" burden of proof, was rejected in both the Appellate Division of the New York Supreme Court and in the New York Court of Appeals before the Supreme Court granted certiorari.
Does the requirement that juvenile convictions rest on "preponderance of the evidence" burden of proof, as opposed to that stricter "beyond a reasonable doubt" threshold, violate the Fourteenth Amendment's Due Process Clause?
Yes. In a 5-to-3 decision, the Court found that when establishing guilt of criminal charges the strict "reasonable-doubt" standard must be applied to both adults and juveniles alike. The Court noted that by establishing guilt based only on a "preponderance of the evidence," as is customary in civil cases, courts were denying criminal defendants a fundamental constitutional safeguard against the possibility that their fate be incorrectly decided due to fact-finding errors. The Court concluded that mere variations in age among criminal defendants will not suffice to warrant the use of different burdens of proof so long as they all face loss of liberty as a possible sentence.
Decisions
Decision: 5 votes for In re Winship, 3 vote(s) against Legal provision: Due Process
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Full Opinion by Justice William J. Brennan, Jr.
