The Oyez Project: Civil Rights Issues - Juveniles Decisions

Ankenbrandt, As Next Friend And Mother Of L. R. v. Richards

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Breed v. Jones

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DeShaney v. Winnebago County

Does a state's failure to protect an individual against private violence constitute a violation of the Due Process Clause of the Fourteenth Amendment?

No. The Due Process Clause does not impose a special duty on the State to provide services to the public for protection against private actors if the State did not create those harms. "The Clause is phrased as a limitation on the State's power to act, not as a guarantee of certain minimal levels of safety and security; while it forbids the State itself to deprive individuals of life, liberty, and property without due process of law, its language cannot fairly be read to impose an affirmative obligation on the State to ensure that those interests do not come to harm through other means."

Dorszynski v. United States

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Durst v. United States

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In re Gault

Were the procedures used to commit Gault constitutionally legitimate under the Due Process Clause of the Fourteenth Amendment?

No. The proceedings of the Juvenile Court failed to comply with the Constitution. The Court held that the proceedings for juveniles had to comply with the requirements of the Fourteenth Amendment. These requirements included adequate notice of charges, notification of both the parents and the child of the juvenile's right to counsel, opportunity for confrontation and cross-examination at the hearings, and adequate safeguards against self-incrimination. The Court found that the procedures used in Gault's case met none of these requirements.

In Re Whittington

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In re Winship

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.

Kent v. United States

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M.L.B V. S.L.J.

May a State, consistent with the Due Process and Equal Protection Clauses of the Fourteenth Amendment, condition appeals from trial court decrees terminating parental rights on the affected parent's ability to pay record preparation fees?

No. In a 6-3 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that, just as a State may not block an indigent petty offender's access to an appeal afforded others, so Mississippi may not deny M.L.B., because of her poverty, appellate review of the sufficiency of the evidence on which the trial court found her unfit to remain a parent. "We place decrees forever terminating parental rights in the category of cases in which the State may not 'bolt the door to equal justice,'" wrote Justice Ginsburg, "recognizing that parental termination decrees are among the most severe forms of state action." Chief Justice William H. Rehnquist and Justices Clarence Thomas and Antonin Scalia dissented.

Mckeiver v. Pennsylvania

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New Jersey v. T.L.O.

Did the search violate the Fourth and Fourteenth Amendments?

No. Citing the peculiarities associated with searches on school grounds, the Court abandoned its requirement that searches be conducted only when a "probable cause" exists that an individual has violated the law. The Court used a less strict standard of "reasonableness" to conclude that the search did not violate the Constitution. The presence of rolling papers in the purse gave rise to a reasonable suspicion in the principal's mind that T.L.O. may have been carrying drugs, thus, justifying a more thorough search of the purse.

Parham v. J. R.

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Ralston v. Robinson

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Santosky v. Kramer

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Schall v. Martin

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Secy. Of Pub. Welf. v. Institutionalized Juveniles

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Swisher v. Brady

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Tuten v. United States

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United States v. R. L. C.

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Washington Dept. of Social & Health Services v. Guardianship of Keffeler

Does the State of Washington's use of foster childrens' Social Security benefits to reimburse itself for some of its expenditures violate the provision of the Social Security Act that protects benefits from "execution, levy, attachment, garnishment, or other legal process?"

No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that the state's use of the Social Security benefits to reimburse itself does not violate the Social Security Act's anti-attachment provision. The Court reasoned that the Department's effort to become a representative payee and its use of Social Security benefits did not amount to employing an "execution, levy, attachment, garnishment, or other legal process" within the meaning of the provision. The Court also noted that a ruing adverse to the state could disadvantage children in foster care.