## Facts

- Christopher Lyance Chatman, age 13, was charged in juvenile court with delinquency based on malicious wounding under Va. Code § 18.2-51.
- The juvenile court adjudicated Chatman delinquent upon a finding of unlawful wounding.
- Chatman appealed to the Circuit Court of Greensville County for a de novo adjudicatory proceeding.
- In circuit court, Chatman moved for a psychiatric evaluation to support an insanity defense, asserting a history of mental illness; he had been noted to have homicidal ideations, and a psychologist later diagnosed him with schizophreniform disorder.
- The Commonwealth conceded that an adult defendant with comparable allegations would be entitled to an evaluation to pursue an insanity defense, but argued juveniles have no such right at the adjudicatory phase of delinquency proceedings.
- The circuit court denied the psychiatric-evaluation motion, found Chatman delinquent for unlawful wounding after a bench trial, and committed him to the Department of Youth and Family Services.
- The Court of Appeals held due process and “fair treatment” required allowing juveniles to raise an insanity defense at adjudication.
- The Supreme Court of Virginia granted the Commonwealth’s appeal.

## Issues

1. Whether the Due Process Clause of the Fourteenth Amendment requires that a juvenile be permitted to assert an insanity defense at the adjudicatory phase of a delinquency proceeding.
2. Whether Virginia statutes confer a right for juveniles to assert an insanity defense, or obtain a psychiatric evaluation for that purpose, at the adjudicatory phase of delinquency proceedings.

## Decision

- The Supreme Court of Virginia reversed the Court of Appeals and reinstated the circuit court’s judgment.
- The court held juveniles have no constitutional right to an insanity defense at the adjudicatory phase of delinquency proceedings.
- The court held Virginia’s juvenile statutory scheme does not provide an insanity defense at adjudication, and courts should not create one absent legislative action.
- Because no such right existed, the circuit court did not err in denying the psychiatric evaluation sought to support an insanity defense.

## Legal Principles

- Due process does not require states to provide an insanity defense in criminal proceedings; therefore, due process does not compel an insanity defense in juvenile delinquency adjudications.
- Juvenile delinquency proceedings must satisfy the essentials of due process and fair treatment, but procedural protections in juvenile court are not necessarily identical to those in adult criminal prosecutions.
- Competency to participate in proceedings (a due process requirement) is distinct from insanity at the time of the offense; recognition of competency safeguards does not imply a right to an insanity defense.
- Where the General Assembly has created adult insanity-defense procedures but has not provided parallel provisions for juveniles at adjudication, courts will not infer or judicially create such a defense; the choice is legislative.

## Conclusion

The Supreme Court of Virginia held that neither the Fourteenth Amendment nor Virginia statutes grant juveniles a right to assert an insanity defense at the adjudicatory phase of delinquency proceedings, and it reinstated the delinquency adjudication entered after denial of a psychiatric evaluation sought for that purpose.


Commonwealth v. Chatman, 538 S.E.2d 304 (Va. 2000)