Landmark Juvenile Cases
Landmark juvenile cases are significant court cases involving juveniles, which have
historical and legal significance.
Case: Breed v. Jones
Citation Number: 421 U.S. 519 (1975)
Date of Trial: February 25 - 26, 1975
Date of Decision: May 27, 1975
Location: United Sates Court of Appeals for the Ninth Circuit
Petitioner: Allen F. Breed, Director of California Youth Authority
Respondent: Gary Steven Jones
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Summary of Case:
Gary Jones (17) was an adjudicated delinquent in juvenile court, and was then tried
as an adult in criminal court for the same robbery offense. Jones filed for a writ of
habeas corpus (a petition demanding determination on if the state's detention of a
prisoner is valid), but was denied by the Supreme Court of California prior to his
adult criminal trial. He sought habeas corpus again in Federal district court following
his conviction for robbery, but was denied once again.
The U.S. Court of Appeals for the Ninth Circuit reversed this decision, holding that
the adult criminal trial violated the Double Jeopardy Clause (the prosecution of a
person twice for the same offense).
The U.S. Supreme Court agreed with this decision.
Consideration:
Did Gary Jones’s trial in adult criminal court following his adjudication in juvenile
court for the same offense constitute as a violation of the Double Jeopardy Clause?
Decision:
Yes. The Supreme Court determined juveniles tried and adjudicated in juvenile court
cannot be tried as an adult in criminal court for the same criminal act, doing so would
violate the Double Jeopardy Clause.
Future Impact:
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.
Courts cannot try a juvenile twice in the two different levels of court for the same
crime, thus minimizing the number of juvenile transfers to adult courts.
Accompanies: Juveniles in the Criminal Justice System
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Landmark Juvenile Cases
Case: In re Gault
Citation Number: 387 US 1 (1961)
Date of Trial: December 6, 1966
Date of Decision: May 15, 1967
Location: Gila County Youth Detention Center
Appellant: Gerald Francis Gault
Appellee: State of Arizona
Summary of Case:
Gerald Gault (15) was accused of making an obscene telephone call to a neighbor,
Mrs. Cook, and was arrested with his friend Ronald Lewis after the neighbor filed a
complaint. Police did not notify Gault’s parents or leave any notice.
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Throughout the court hearings, Gault was denied the right to an attorney, was not
formally notified of the charges against him, was not informed of his right against
self-incrimination and was not provided an opportunity to confront his accusers.
Three hearings were held. No witnesses were sworn in and neither the petition nor
probation report were provided to Gault or his parents. Despite Gault’s mother’s
requests, Mrs. Cook did not appeared to identify which of the two young men
committed the crime.
Gault was sentenced to six years at the State Industrial School until he reached 21
years old. An adult’s maximum sentence would be two months in jail and a $50 fine.
Gault’s parents unsuccessfully appealed the higher Arizona courts, but the United
States Supreme Court granted certiorari (a writ or order by which a higher court
reviews a decision of a lower court) to review the case.
Consideration:
Did Arizona’s Juvenile Code violate the Due Process Clause of the 14th Amendment
of the United States Constitution, due to provisions regarding notice; right to counsel;
the right to confront witnesses; and the privilege against self-incrimination?
Decision:
Yes. The Supreme Court unanimously reversed and remanded Gault’s sentence,
citing lower the courts had violated the Due Process Clause during his hearings.
Future Impact:
Due process of law is the primary foundation of individual freedom, juvenile or adult.
The 6th and 14th Amendments apply to both juveniles and adults. Juveniles have
the right to be notified of any charges against them, to remain silent, to have an
attorney present, to have a parent present, to not self-incriminate and to confront
their accuser.
Accompanies: Juveniles in the Criminal Justice System
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Landmark Juvenile Cases
Case: McKeiver v. Pennsylvania
Citation Number: 407 US 528 (1971)
Date of Trial: December 9 - 10, 1970
Date of Decision: June 21, 1971
Location: Juvenile Court of Philadelphia
Appellant: Joseph McKeiver et al.
Appellee: Pennsylvania
Summary of Case:
This case is the consolidation of several juvenile cases from both Pennsylvania and
North Carolina.
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In Pennsylvania, two juveniles (15 and 16 years old) were denied a jury trial in
juvenile court. In North Carolina, several students (ages ranging from 11 to 15) were
charged with disorderly conduct and were denied a jury trial in juvenile court.
All juveniles in these cases appealed the denial of their requests for jury trials to their
State Supreme Courts. Both State Supreme Courts affirmed the denial of jury trials.
The United States Supreme Court granted certiorari for the cases from both states,
but affirmed the decisions by both State Supreme Courts.
Consideration:
Does the 6th Amendment right to a jury trial, as applied to the states by the Due
Process Clause of the 14th Amendment, apply to juveniles?
Decision:
No. The Supreme Court concluded the 6th Amendment does not grant juveniles the
right to a jury trial in juvenile court.
Future Impact:
The Supreme Court held onto the idea of juvenile courts being fundamentally
different in purpose and approach than adult criminal court, which is emphasized by
denying juveniles the right to a trial by jury when in juvenile court, despite juveniles
being protected by the Due Process Clause.
Accompanies: Juveniles in the Criminal Justice System
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Landmark Juvenile Cases
Case: Graham v. Florida
Citation Number: 560 US 48 (2010)
Date of First Trial: May 4, 2009
Date of Second Trial: November 9, 2009
Date of Decision: May 17, 2010
Location: Florida Supreme Court
Petitioner: Terrance Jamar Graham
Respondent: Florida
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Summary of Case:
Terrence Graham was convicted of armed burglary and attempted armed robbery of
a restaurant at 16 years old. Graham served a 12-month sentence. Only six months
later, Graham was tried and convicted by a Florida state court of armed home
robbery and sentenced to life in prison without parole.
Graham appealed this decision, challenging the courts a life sentence without parole
on a juvenile violated the 8th Amendment and constituted cruel and unusual
punishment, thus violating the 8th Amendment even further.
The Florida District Court of Appeals disagreed with Graham’s claims and held
Graham's sentence was neither a violation of the 8th Amendment nor constituted
cruel and unusual punishment.
Consideration:
Does a life sentence without parole of a juvenile convicted of a non-homicidal
offense violate the 8th Amendment's prohibition of "cruel and unusual punishment?"
Decision:
Yes. The Supreme Court determined sentencing a juvenile offender to life in prison
without parole for a non-homicidal crime is a violation of the 8th Amendment's Cruel
and Unusual Punishments Clause.
Future Impact:
The Supreme Court determined the Court must:
1) consider objective evidence of society's standards
2) determine whether the punishment in question violates the Constitution
guided by the standards elaborated by controlling precedents (previous
cases)
Here, the Court concluded both (1) and (2) indicated the punishment in question for
juvenile cases was unconstitutional.
Accompanies: Juveniles in the Criminal Justice System
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Landmark Juvenile Cases
Additional landmark juvenile cases for further research:
 Kent v. United States (1966)
 Tinker v. Des Moines Independent School District (1969)
 In re Winship (1970)
 Smith v. Daily Mail Publishing Co. (1979)
 Schall v. Martin (1984)
 Roper v. Simmons (2005)
 J.D.B. v. North Carolina (2011)
 Miller v. Alabama (2012)
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6th Amendment:
 “In all criminal prosecutions, the accused shall enjoy the right to a speedy
and public trial, by an impartial jury of the state and district wherein the
crime shall have been committed, which district shall have been previously
ascertained by law, and to be informed of the nature and cause of the
accusation; to be confronted with the witnesses against him; to have
compulsory process for obtaining witnesses in his favor, and to have the
assistance of counsel for his defense.”
8th Amendment:
 “Excessive bail shall not be required, nor excessive fines imposed, nor cruel
and unusual punishments inflicted.”
14th Amendment:
 Section 1 - “All persons born or naturalized in the United States, and subject
to the jurisdiction thereof, are citizens of the United States and of the state
wherein they reside. No state shall make or enforce any law which shall
abridge the privileges or immunities of citizens of the United States; nor
shall any state deprive any person of life, liberty, or property, without due
process of law; nor deny to any person within its jurisdiction the equal
protection of the laws.”
Accompanies: Juveniles in the Criminal Justice System
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