## Facts

- John Jarvis, identified in the opinion as the juvenile respondent, was proceeded against in the Massachusetts Juvenile Court on a delinquency complaint brought by the Commonwealth.
- The case was tried to a jury in the juvenile session.
- During the Commonwealth’s case-in-chief, the Commonwealth introduced no testimony, documents, or stipulation admitted in evidence to establish that Jarvis was between seven and seventeen years old.
- At the close of the Commonwealth’s evidence, Jarvis moved for a directed verdict (required finding) of not guilty on the ground that the Commonwealth had failed to establish that he was a juvenile within the statutory age range for delinquency.
- After a hearing, the Juvenile Court judge denied the motion.
- The judge instructed the jury that, to return a delinquency adjudication, they had to find beyond a reasonable doubt that Jarvis was between seven and seventeen years of age, in addition to finding the required misconduct.
- The jury adjudicated Jarvis a delinquent child.
- Jarvis appealed, arguing that the denial of his motion was error because the Commonwealth presented no evidence of age for the jury to consider.

## Issues

1. Must the Commonwealth prove beyond a reasonable doubt, in a delinquency proceeding, that the respondent was between seven and seventeen years old?
2. If the Commonwealth introduced no evidence of the respondent’s age at trial, does that omission require reversal of the delinquency adjudication on appeal in the circumstances of this case?

## Decision

- The Appeals Court treated the respondent’s age (seven to seventeen) as a fact the Commonwealth must establish beyond a reasonable doubt to support an adjudication of delinquency.
- The court nevertheless affirmed the adjudication, concluding that reversal was not required on this record where the proceeding was conducted throughout as a juvenile matter and the respondent’s juvenile status was not genuinely in dispute in the way the case was tried and submitted to the jury.

## Legal Principles

- A delinquency adjudication requires proof, beyond a reasonable doubt, that the respondent fits within the statutory definition of a “delinquent child,” including being within the juvenile age range.
- The age component distinguishes a delinquency matter from an adult criminal prosecution and is a fact for the factfinder under the reasonable-doubt standard when the case is tried to a jury.
- Appellate review of an omission in proof may consider how the case was actually tried, including whether the parties and the court proceeded on an uncontested assumption about the respondent’s juvenile status.
- Where the entire proceeding reflects treatment of the respondent as a juvenile and there is no real dispute that the respondent falls within the juvenile age range, the absence of formal age proof admitted at trial does not automatically require reversal in every case.

## Conclusion

Commonwealth v. A Juvenile holds that the Commonwealth bears the burden to prove the respondent’s juvenile age range beyond a reasonable doubt in delinquency proceedings, but it affirms a delinquency adjudication despite the lack of affirmative age evidence where the case was tried in Juvenile Court on the shared, uncontested premise that the respondent was a juvenile within the statutory range.


Commonwealth v. A Juvenile, 534 N.E.2d 809 (1989)