## Facts

- Morris A. Kent, Jr., age 16, was arrested in the District of Columbia in connection with housebreaking, robbery, and rape charges.
- Under the District of Columbia Juvenile Court Act, the Juvenile Court had exclusive jurisdiction unless it waived jurisdiction after a “full investigation.”
- Kent’s counsel sought (1) a hearing on the waiver question and (2) access to Kent’s Social Service file and related probation materials.
- The Juvenile Court did not rule on either request and entered a waiver order stating only that a “full investigation” had occurred, without explanation.
- After waiver, Kent was indicted in federal district court; the court denied his motion to dismiss for invalid waiver.
- Kent was convicted on six counts of housebreaking and robbery, found not guilty by reason of insanity on two rape counts, and sentenced to 30–90 years’ imprisonment.
- The court of appeals affirmed, and the Supreme Court granted review.

## Issues

1. Whether a Juvenile Court waiver of jurisdiction is valid when entered without a hearing, without counsel’s access to social records considered by the court, and without a statement of reasons.
2. Whether the Juvenile Court Act’s “full investigation” requirement, read with due process and the right to counsel, requires procedural protections and a reviewable record for waiver decisions.
3. What remedy is appropriate when the waiver process was defective but the juvenile may have aged out of Juvenile Court jurisdiction.

## Decision

- The Supreme Court reversed and remanded, holding the waiver order invalid.
- The Court held that Juvenile Court discretion to waive jurisdiction is limited by statutory requirements and “basic requirements of due process and fairness.”
- The Court required, for waiver proceedings, a hearing, counsel access to relevant social-service and probation records, and a statement of reasons sufficient for meaningful appellate review.
- The Court directed the district court on remand to determine whether waiver would have been proper under correct standards; if not, Kent’s conviction had to be vacated.

## Legal Principles

- Waiver of Juvenile Court jurisdiction is a “critically important” determination affecting substantial statutory rights and exposure to adult criminal penalties.
- The rehabilitative rationale of juvenile court (parens patriae) does not justify arbitrary procedure when liberty interests are at stake.
- A valid waiver decision requires procedural regularity: notice and hearing, effective assistance of counsel supported by access to relevant records, and reasoned findings adequate for appellate review.
- Statutory terms such as “full investigation” must be applied in a manner consistent with due process and the right to counsel.

## Conclusion

The Court held that transferring a juvenile to adult court cannot be done through unreviewable, informal process; waiver requires a hearing, counsel access to the records relied upon, and stated reasons sufficient to permit meaningful appellate review, with a conditional remand to determine whether waiver was substantively justified.


Kent v. United States, 383 U.S. 541 (1966)