## Facts

- Ten-year-old Deborah Coleman disappeared from near her Jersey City home on June 29–30, 1964.
- On July 2, 1964, police found her body in a cellar of a nearby tenement building; an autopsy determined death by strangulation.
- Juvenile delinquency complaints were filed in Hudson County Juvenile Court against Jose Angel Carlo (age 13) and Thomas Stasilowicz (age 15), alleging conduct that would constitute second-degree murder if committed by an adult.
- The juvenile matters were consolidated and tried in “extensive hearings” where:
  - The State was represented by the county prosecutor.
  - Each juvenile was represented by counsel.
  - A stenographic transcript was made.
- The juvenile court adjudicated both juveniles delinquent for acts equivalent to second-degree murder.
- The court committed Stasilowicz to the State Reformatory at Annandale and Carlo to the State Home for Boys, each for an indeterminate period.
- The juveniles appealed; the New Jersey Supreme Court granted certification on its own motion before the Appellate Division decided the case.

## Issues

1. Whether juvenile delinquency proceedings based on homicide-level conduct must provide procedural protections sufficient to satisfy due process despite being labeled noncriminal.
2. Whether the evidence presented was sufficiently reliable and adequate to support delinquency adjudications based on acts equivalent to second-degree murder.
3. What level of proof and fact-finding rigor is required in serious juvenile delinquency cases resulting in substantial confinement.

## Decision

- The New Jersey Supreme Court affirmed the delinquency adjudications and the resulting commitments.
- The Court held that, given the protections actually provided (counsel, adversarial hearings, and a verbatim record), the proceedings satisfied fundamental fairness requirements.
- The Court concluded the record contained substantial, credible evidence adequate to support findings that the juveniles committed acts that would constitute second-degree murder if committed by adults.
- The Court emphasized that juvenile courts must treat serious delinquency matters as formal adjudications rather than informal interventions when significant liberty interests are at stake.

## Legal Principles

- Juvenile delinquency proceedings, though formally civil, must conform to basic due process when they expose juveniles to serious confinement and stigma.
- In grave juvenile cases, fairness requires meaningful adversarial process, including representation by counsel and a reviewable record.
- Adjudications for felony-equivalent conduct must rest on substantial and reliable evidence commensurate with the seriousness of the allegations and disposition.
- Appellate review should respect juvenile court fact-finding when supported by credible evidence in a properly conducted adjudicatory hearing.

## Conclusion

The court upheld the homicide-based delinquency findings and commitments, while making clear that juvenile proceedings with severe consequences must be conducted with robust procedural protections and evidentiary rigor, notwithstanding the juvenile system’s nominally noncriminal label.


In re State in the Interest of Carlo, 48 N.J. 224, 225 A.2d 110 (N.J. 1966)