## Facts

- Oklahoma law defined a “child” for juvenile-court purposes as any male under 16 and any female under 18.
- Danny Ray Lamb, a 17-year-old male, was excluded from juvenile-court jurisdiction solely because of his sex and age.
- Oklahoma prosecuted Lamb in adult criminal court for felony burglary of an automobile.
- Lamb argued the statute’s sex-based disparity denied equal protection by granting juvenile treatment to 16- and 17-year-old females but not similarly situated males.
- Oklahoma appellate courts had upheld the statute as a legislative judgment based on “demonstrated facts of life.”
- Lamb sought federal habeas corpus relief after his adult conviction, asserting the statutory classification was unconstitutional.

## Issues

1. Whether Oklahoma’s juvenile-code definition of “child,” extending juvenile jurisdiction to females under 18 but only to males under 16, violated the Equal Protection Clause of the Fourteenth Amendment.

## Decision

- The Tenth Circuit reversed the denial of habeas relief.
- The court held the sex-based age distinction in juvenile-court eligibility constituted invidious discrimination against males under the Equal Protection Clause.
- The court declared the discriminatory statutory definition unconstitutional as applied to juvenile-court eligibility.
- Because Lamb was tried as an adult only due to the unconstitutional classification, the court set aside the adult conviction and granted habeas relief.

## Legal Principles

- States may create legislative classifications, including in criminal and juvenile systems, but classifications must have a constitutionally sufficient justification and may not be invidious.
- A categorical rule granting juvenile-court treatment to females aged 16–17 while denying it to males of the same age is an equal-protection violation absent an adequate justification.
- Generalized assumptions about sex differences (e.g., asserted “facts of life”) do not, without supporting justification, validate a sex-based deprivation of access to juvenile-court protections.

## Conclusion

The Tenth Circuit held that Oklahoma’s sex-based juvenile-court age cutoff impermissibly treated similarly situated 16- and 17-year-old males more harshly than females, violating equal protection; it therefore granted habeas relief and invalidated Lamb’s adult conviction obtained under the discriminatory scheme.


Lamb v. Brown, 456 F.2d 18 (10th Cir. 1972)