Friday, November 15, 2013

In re Winship case brief

In re Winship case brief summary
397 U.S. 358 (1970)

Petitioner, on behalf of a juvenile, sought review of a judgment from the Court of Appeals of New York that the determinations to be made at a juvenile adjudicatory hearing were to be based on a preponderance of the evidence, as provided in N.Y. Fam. Ct. Act § 744 (b).

Petitioner appeared on a juvenile's behalf at his adjudicatory proceeding to determine his delinquency. The juvenile had been charged with committing acts that, had they been done by an adult, would have been larceny. The juvenile court made its determination based on a preponderance of the evidence presented, relying on N.Y. Fam. Ct. Act § 744(b), and ordered him to a training school for 1 1/2 years, with possible extensions to his 18th birthday.

  • The Supreme Court found that the same concerns that led to the establishment of proof beyond a reasonable doubt in criminal matters were no less evident in a juvenile proceeding, and particularly in this case where the juvenile was charged with an act that rendered him liable to confinement for up to six years. 
  • The Court rejected respondent city's argument that delinquency adjudications were not convictions and would have no effect on his citizenship rights or privileges. 
  • The Court acknowledged that the underlying policy of the juvenile justice system was rehabilitation, but that none of the substantive benefits of the juvenile process would be compromised by adopting the higher standard of proof.

The judgment that a determination of whether a juvenile committed an act was to be based on a preponderance of the evidence was reversed. The constitutional safeguard of proof beyond a reasonable doubt was required during the adjudicatory stage of a delinquency proceedings, and the New York statute providing to the contrary was unconstitutional.

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