Friday, November 15, 2013

McKeiver v. Pennsylvania case brief

McKeiver v. Pennsylvania case brief summary
403 U.S. 528 (1971)


CASE SYNOPSIS
On appeal of several cases in which juveniles were adjudicated delinquent, certiorari was issued to the Supreme Court of Pennsylvania and the Supreme Court of North Carolina to determine whether the Due Process Clause of U.S. Constitutional amendment XIV assured the right to trial by jury in the adjudicative phase of state juvenile court delinquency proceedings.

CASE FACTS
Several juveniles were adjudicated delinquent after their jury trial demands were denied.

DISCUSSION

  • The Supreme Court affirmed the judgments because the right to trial by jury in the adjudicative phase of a state juvenile court delinquency proceeding was not guaranteed by the Due Process Clause of U.S. Constitutional amendment XIV. 
  • The Court distinguished the nature and purpose of the juvenile court proceeding from a criminal proceeding and noted that all rights constitutionally assured for the adult accused had not traditionally been imposed upon the state juvenile proceeding. 
  • The Court found that the applicable due process standard in both proceedings was fundamental fairness. 
  • To that end, the Court noted the requirements of notice, counsel, confrontation, cross-examination, and standard of proof in juvenile proceedings. 
  • However, the Court determined that the legal system did not always regard a jury as a necessary component of accurate factfinding and noted that juries were not required in equity, workmen's compensation, probate, or deportation cases. 
  • The Court concluded that trial by jury in the juvenile court's adjudicative stage was not a constitutional requirement.

CONCLUSION
The Court affirmed the judgments that adjudicated several juveniles delinquent without a jury trial and held that there was no constitutional right to a jury trial in juvenile court.



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