## Facts

- California filed a juvenile-court petition alleging that 17-year-old Gary Steven Jones committed armed robbery and was a delinquent.
- The juvenile court held a full adjudicatory hearing to determine whether Jones committed acts violating a criminal law.
- After hearing evidence, the juvenile court found Jones committed the robbery.
- At a later dispositional stage, the juvenile court found Jones unfit for juvenile treatment and ordered adult criminal prosecution.
- The State charged Jones in adult court for the same robbery, and he was convicted of first-degree robbery.
- Jones sought habeas relief, arguing the adult prosecution violated the Double Jeopardy Clause; state courts denied relief.
- In federal habeas proceedings, the district court denied relief, but the Ninth Circuit reversed, holding the adult prosecution was constitutionally barred.

## Issues

1. Whether the Double Jeopardy Clause applies to juvenile delinquency adjudicatory proceedings.
2. When jeopardy attaches in a juvenile proceeding that adjudicates whether the juvenile committed a criminal offense.
3. Whether a state may prosecute a juvenile as an adult for the same offense after a juvenile court has conducted an adjudicatory hearing and made a finding on the merits.

## Decision

- The Supreme Court unanimously held that the Double Jeopardy Clause applies to juvenile adjudicatory proceedings that determine whether the juvenile committed a criminal offense.
- The Court held that jeopardy attached when the juvenile court, acting as factfinder, began to hear evidence at the adjudicatory hearing.
- Because Jones was later tried in adult court for the same robbery after the juvenile adjudication on the merits, the adult prosecution violated the Double Jeopardy Clause (as applied to the States through the Fourteenth Amendment).
- The Court vacated and remanded for further proceedings consistent with its opinion.

## Legal Principles

- Jeopardy attaches in a juvenile delinquency adjudicatory hearing when the court begins to hear evidence on whether the juvenile committed acts constituting a criminal offense.
- The Double Jeopardy Clause protects against being subjected to successive trials for the same offense, not merely against multiple punishments.
- Distinctions between juvenile and adult systems do not justify a general exception permitting a second trial after a merits adjudication in juvenile court.
- If a state seeks to try a juvenile as an adult, the transfer/waiver determination must be made before any adjudicatory hearing on guilt occurs in juvenile court.

## Conclusion

A juvenile may not be subjected to an adult criminal trial for the same offense after a juvenile court has already held an adjudicatory hearing and determined the juvenile committed the charged criminal act, because that sequence places the juvenile twice in jeopardy.


Breed v. Jones, 421 U.S. 519 (1975)