## Facts

- The State filed a juvenile delinquency petition alleging C.T.F. committed a delinquent act.
- The adjudicatory (fact-finding) hearing was scheduled to begin slightly more than four months after the petition was filed.
- C.T.F. moved to dismiss, claiming the delay violated a speedy-trial right.
- The juvenile court denied dismissal, noting C.T.F. offered no evidence of prejudice, and proceeded to adjudicate C.T.F. delinquent.
- The juvenile court placed C.T.F. on probation and released him to his father’s custody.
- C.T.F. appealed, challenging the denial of his speedy-trial claim and the legal premise that juveniles categorically lack speedy-trial protections in delinquency proceedings.

## Issues

1. Whether the Sixth Amendment and Iowa Constitution article I, section 10 speedy-trial guarantees apply to juvenile delinquency proceedings.
2. Whether Iowa Rule of Criminal Procedure 27(2)(b) applies to juvenile delinquency adjudications.
3. Whether a delay of a little over four months violated any due-process-based right to timely adjudication where the juvenile showed no specific prejudice.

## Decision

- The Iowa Supreme Court affirmed the delinquency adjudication and disposition.
- The court held the Sixth Amendment and Iowa Constitution speedy-trial clauses, by their terms limited to “criminal prosecutions,” do not directly govern juvenile delinquency proceedings.
- The court held any protection against undue delay in juvenile delinquency proceedings arises, if at all, from due process and is evaluated for fundamental fairness.
- The court held Iowa Rule of Criminal Procedure 27(2)(b) does not apply in juvenile delinquency proceedings.
- The court concluded the approximately four-month delay, without evidence of prejudice or unfairness, did not violate due process.

## Legal Principles

- Juvenile delinquency proceedings are not “criminal prosecutions” for purposes of the Sixth Amendment and Iowa Constitution article I, section 10 speedy-trial guarantees.
- Procedural protections in delinquency cases are determined under the Fourteenth Amendment’s due process requirement of fundamental fairness, assessed case by case.
- Criminal speedy-trial rules do not automatically apply in juvenile court absent an applicable juvenile rule or statute.
- A due-process claim based on delay generally requires a showing that the delay caused actual prejudice or otherwise rendered the proceeding unfair; elapsed time alone is insufficient on these facts.

## Conclusion

The court upheld the adjudication and probationary disposition, ruling that constitutional speedy-trial clauses and Iowa’s criminal speedy-trial rule do not control juvenile delinquency proceedings, and that the modest delay shown—without evidence of prejudice—did not deny due process.


In re C.T.F., 316 N.W.2d 865 (Iowa 1982)