## Facts

- A juvenile delinquency petition alleged Steven G. committed conduct amounting to second-degree robbery arising from a robbery at a natural-foods store.
- Trial began in juvenile court; the state presented at least one witness and the defense cross-examined.
- After a continuance and after trial had commenced, the state moved (with notice to Steven G. and counsel) to amend the petition under Connecticut Practice Book § 1029 to add four additional charges tied to the same robbery episode.
- Over objection, the juvenile court allowed the amendment and denied a motion to dismiss the added counts.
- Following trial on the amended petition, the juvenile court adjudicated Steven G. delinquent.
- The Appellate Court affirmed, applying a “fundamental fairness” standard to mid-trial amendments in juvenile cases.
- The Connecticut Supreme Court granted certification to decide the governing standard and whether the amendment was proper.

## Issues

1. What standard governs the state’s ability to amend a juvenile delinquency petition after trial has begun: strict adult criminal pleading limits or a juvenile “fundamental fairness” standard?
2. Under the proper standard, did adding four charges mid-trial violate due process by unfairly prejudicing Steven G.’s ability to understand the charges and defend?

## Decision

- The Connecticut Supreme Court affirmed.
- The court held that mid-trial amendment of a juvenile delinquency petition is governed by “fundamental fairness,” not strict adult criminal pleading and amendment rules.
- The court concluded the amendment was permissible because the added counts arose from the same incident, the juvenile had notice, and the record did not show prejudicial surprise or impairment of the defense.

## Legal Principles

- Juvenile delinquency proceedings must satisfy due process and fair treatment, but they are not treated as formal adult criminal prosecutions for purposes of technical pleading rules.
- A juvenile delinquency petition may be amended after trial begins if the amendment is consistent with fundamental fairness, including fair notice of the conduct charged and a meaningful opportunity to defend.
- Practice Book § 1029 permits amendments that do not cause injustice or unfair surprise; whether an amendment is allowed depends on case-specific prejudice to the juvenile’s defense.

## Conclusion

Connecticut permits substantive mid-trial amendments to juvenile delinquency petitions when the change is tied to the same underlying conduct and, in light of notice and opportunity to defend, the proceeding remains fundamentally fair.


In re Steven G., 210 Conn. 435, 556 A.2d 131 (1989)