## Facts

- Two young girls (ages six and seven) were found dead in woods in Rockaway Township, New Jersey, with severe blunt-force head injuries; one also had knife wounds.
- H.C., age 15, was apprehended the next day and charged in juvenile court with delinquency based on the killings.
- At the hearing, forensic evidence and H.C.’s statement established that he struck the fatal blows; the conduct itself was essentially uncontested.
- After the killings, H.C. left the bodies, returned home, changed blood-stained clothing, interacted normally with his family, and went to bed without his parents noticing anything unusual.
- Three psychiatrists (one for the State, two for the defense) diagnosed H.C. with schizophrenia and generally agreed he experienced compelling voices and severe impairments affecting understanding and control.
- A facility evaluation similarly diagnosed schizophrenia, attributed the killings to the illness, and recommended inpatient treatment while warning of possible premature discharge due to resource limits.
- The defense argued that, due to mental disease, H.C. met the M’Naghten standard and therefore should not be adjudicated delinquent for conduct paralleling adult murder.

## Issues

1. Whether a juvenile may avoid a delinquency adjudication for homicide-based conduct by establishing insanity under the M’Naghten standard.
2. How a juvenile court should structure disposition for a seriously mentally ill juvenile who committed a double homicide, balancing treatment needs and public safety given institutional limitations.

## Decision

- The court adjudicated H.C. delinquent notwithstanding substantial evidence of schizophrenia and impaired capacity.
- The court declined to treat satisfaction of M’Naghten as a categorical bar to a delinquency finding in juvenile proceedings.
- The court ordered a custodial disposition within the juvenile system aimed at maintaining state control and securing psychiatric treatment while protecting the public.

## Legal Principles

- Juvenile delinquency proceedings are primarily civil and rehabilitative; criminal-law insanity doctrine does not automatically control delinquency status.
- In juvenile cases involving serious mental illness, insanity-type evidence is highly relevant to disposition, particularly the need for treatment and structured supervision, even if it does not negate delinquency.
- Where mental-health institutions may be unable to provide sustained custody or treatment, juvenile jurisdiction may be used to impose a longer-term custodial framework consistent with public safety and therapeutic needs.

## Conclusion

The court held that M’Naghten insanity was not a complete defense to delinquency in this juvenile homicide case, and it treated severe mental illness chiefly as a dispositional factor, using juvenile custody to ensure both psychiatric treatment and protection of the public.


In re H.C., 106 N.J. Super. 583, 256 A.2d 322 (N.J. Super. Ct. Juv. & Dom. Rel. Ct. 1969)