Juvenile Justice in the United States: A Historical Analysis
February 2024 | Mary Miller (Staff Writer)
Adolescence is the most impressionable period of human life where an emphasis is placed on providing children with guidance and strong values to become law-abiding citizens. [1] However, not all children are afforded the privilege of having strong leaders and mentors, which significantly contributes to delinquent behaviors. [2] Combined with trauma, neglect, and other social factors that increase opportunities for delinquent behavior, it is easy for children to fall into the criminal justice system. Juvenile justice in the United States has historically changed throughout Supreme Court decisions. In fact, the Court has not touched on or spoken up about youth rights since 2016 and has left states to decide the extent of which rights are applied to juveniles. [3] Following the complicated timeline of youth rights through Supreme Court cases presents several arguments on how states approach juvenile justice and what the future looks like for kids who fall into the criminal justice system.
The First Juvenile Court
Up until 1899, juveniles were not only expected, but subjected to the trials and tribulations of the adult court. In courts’ eyes, there were no differences between the adult mind and the growing mind of an adolescent, saying “... children accused of a crime, and children were charged, jailed, and punished as if they were adults.” [4] However, Illinois changed this perspective by establishing the first juvenile court through legislation. The Illinois Juvenile Court Act of 1899 created a separate court for accused criminals under the ages of sixteen. [5] This was the first piece of legislative reform that changed the focus on delinquent youth from punishment to rehabilitation, affording them additional supportive opportunities like confidential court proceedings. [6] Although this was the first step in the right direction towards reformative juvenile justice practices, significant Supreme Court decisions altered the way that juvenile courts approached youth rights.
Juveniles and Interrogation
Due process rights and interrogation protections are a prominent issue in juvenile justice that has been historically represented throughout Supreme Court decisions. Prior to these decisions, juveniles were not afforded the same rights as adults facing criminal charges. These decisions acknowledged a need for juvenile protection, guidance, and rehabilitative opportunities.
Kent v. United States (1966)
In 1966, the Supreme Court ruled on Kent v. United States (1966), wherein the petitioner was a juvenile accused of heinous crimes. [7] The District of Columbia Juvenile Court waived their right to decide on the case without a hearing or investigation, forcing the petitioner to be tried in the adult court where he was ultimately convicted and sentenced at the age of sixteen. [8] Recognizing the issue with remitting trials to adult court, the petitioner appealed and the Supreme Court invalidated the waiver. [9] The implications of this case afforded juveniles due process rights usually extended to adults. By requiring that juvenile courts conduct thorough investigations and ensuring that juveniles retain the same due process rights as adults, the Supreme Court established the principle that juvenile cases should be handled with the utmost care and consideration with the same procedural safeguards extended to adults. [10]
J.D.B v. North Carolina (2011)
After the 1966 ruling of Miranda v. Arizona (1966) established obligations of law enforcement to afford accused individuals statements of due process rights before interrogation, the Supreme Court was again presented with the application of pre-interview statements in regards to juveniles. [11] The petitioner in J.D.B v. North Carolina (2011) was thirteen years old when he was taken into custody and questioned by police officers without first being informed of his rights outlined in Miranda. [12] Due to law enforcement’s authority and the impressionability of the adolescent mind, the minor confessed and provided a written statement following the interrogation. [13] However, because he was never afforded the understanding of his right to counsel, parent supervision, or other rights established through Miranda warnings, the Supreme Court contended that the child’s age should be applied in the informing of due process rights. [14] Applying a juvenile’s age as a relevant factor in the administration of Miranda warnings further granted youth rights that had only been previously applied to adults and extended interrogation protections.
Juveniles and Sentencing
The protections of juveniles from excessive punishments that inhibit their rehabilitative efforts have consistently been approached in Supreme Court cases. Specifically, the court has ruled on the applicability of capital punishment and extensive prison sentences given to juveniles. These rulings set a precedent of confusion in regards to how juvenile criminality should be approached following court procedures.
A. Juveniles and the Death Penalty
The Supreme Court was first presented with juvenile death penalties in 1988. In Thompson v. Oklahoma (1988), the petitioner was a fifteen year old who was tried in adult court, convicted, and sentenced to capital punishment. [15] However, the court contended that the Eighth Amendment's prohibition of cruel and unusual punishment directly applied to juveniles under the age of sixteen largely due to the reduced culpability and increased impressionability of adolescents. [16] Although this was a significant extension of juvenile justice protections, particularly with regard to the minimum age of capital punishment, this ruling was swiftly altered just one year later. Stanford v. Kentucky (1989) further focused on setting age requirements for juvenile death sentences. [17] However, the Court instead ruled that the applicability of protections against capital punishment through the Eighth Amendment did not pertain to juveniles of the ages of sixteen or seventeen. [18] Therefore, the court established that constitutional protections from death sentences as a “cruel and unusual” punishment did apply to juveniles fifteen and under, but not for ages sixteen to eighteen. [19] This contradicting application of death sentences on juveniles lasted for over a decade, up until Roper v. Simmons (2005) overturned Stanford. [20] In 2005, the Supreme Court ruled that the Eighth Amendment’s prohibition of cruel and unusual punishment did in fact apply to juvenile death sentences, including those of the ages sixteen and over. [21] Roper v. Simmons (2005) opened the door for states to focus on rehabilitative efforts rather than irreparable sentencing of minors and further extended criminal protections to convicted juveniles.
B. Life without parole
In 2012, the Court collectively decided on Miller v. Alabama (2012) [22] and Jackson v. Hobbs (2012) [23] as they both pertained to the sentencing of juveniles to life without the possibility of parole. In both cases, minors of the age fourteen were given the extensive punishments and appealed on the same basis as capital punishment, citing the Eighth Amendment's bar on cruel and unusual punishment. [24] In these landmark cases, the Supreme Court concluded that children are constitutionally different from adults, especially in relation to sentencing due to the adolescent mind increase on risk-taking and vulnerability as well as their underdeveloped understanding of consequences. [25] They further concluded that juvenile sentencing requires increased individualized analysis, providing a better opportunity for courts to focus on rehabilitative efforts that juveniles and adults alike had not previously received. [26] Following the ruling of Miller v. Alabama (2012), the Court lastly touched on juvenile sentencing by retroactively extending the previous ruling. In Montgomery v. Louisiana (2016), the petitioner was sentenced to life without parole at the age of seventeen in 1963. Following Miller, he argued for his release or complete resentencing based on his age at the time the crime was committed. [27] The court agreed with Montgomery, requiring states to vacate or reconsider cases where juveniles received sentences of life without parole. [28] As it stands, juveniles are constitutionally unable to receive sentences of life without the possibility of parole given their significant opportunity and potential for rehabilitation.
Looking Forward
It has now been eight years since the Supreme Court last ruled on and extended the rights of juveniles. With every decision, the Court has extensively shed light on the importance of differentiating juveniles from adults in the criminal justice system. The historical analysis of juvenile justice emphasizes the importance of consistently evolving and extending juvenile protections within the criminal justice system.
While progress has been made in the safeguarding of juvenile rights and promoting rehabilitative efforts in the justice system, challenges pertaining to juvenile justice still persist. The eight year gap signals a significant absence of recent decisions advocating and ensuring continued protection of juveniles and advancement of youth justice. As a result, states have significant room to establish and implement their own separate juvenile justice systems, targeting issues like interrogation tactics and sentencing guidelines. This, however, does not create a cohesive application of legal standards and protections for juveniles, undermining their due process rights and creating disparities in the treatment of young offenders. Without further addressing issues in youth justice, there is a significant gap in juvenile justice policies that effectively serve adolescents that fall into the criminal justice system.
Sources
Steinberg, Laurence. 2014. Age of Opportunity : Lessons from the New Science of Adolescence. Boston: Mariner Books, Houghton Mifflin Harcourt.
Ibid.
Montgomery V. Louisiana, 577 U.S. 190 (2016).
“Illinois Juvenile Court Act of 1899.” Ill. Laws 131–137 (1899).
Ibid.
Ibid.
Kent V. United States, 383 U.S. 541 (1966).
Ibid.
Ibid.
Ibid.
J. D. B. V. North Carolina, 564 U.S. 261 (2011).
Ibid.
Ibid.
Ibid.
Thompson V. Oklahoma, 487 U.S. 815 (1988).
Ibid.
Stanford V. Kentucky, 492 U.S. 361 (1989).
Ibid.
Ibid.
Roper V. Simmons, 543 U.S. 551 (2005).
Ibid.
Miller V. Alabama, 567 U.S. 460 (2012).
Jackson v. Hobbs, 10-9647 (2012).
Ibid.
Ibid.
Ibid.
Ibid.
Ibid.