Facts
- Joseph McKeiver (15) and Edward Terry (16) were charged in Philadelphia Juvenile Court with offenses including robbery, larceny, receiving stolen goods, assault, and escape.
- Both juveniles requested jury trials; the juvenile court denied the requests and adjudicated them delinquent.
- In separate North Carolina juvenile proceedings, more than forty juveniles (roughly ages 11–15) were charged largely with misdemeanor conduct linked to school protests.
- The North Carolina juveniles were denied jury trials, and their delinquency proceedings were closed to the public.
- State appellate courts in both Pennsylvania and North Carolina affirmed, holding there was no constitutional right to a jury trial in juvenile court delinquency adjudications.
- The U.S. Supreme Court granted certiorari and consolidated the cases.
Issues
- Whether the Sixth Amendment right to a jury trial, applied to the states through the Fourteenth Amendment, requires a jury in the adjudicative phase of state juvenile delinquency proceedings.
- Whether due process “fundamental fairness” in juvenile court includes a constitutional entitlement to a jury as a required factfinding safeguard.
Decision
- The Court affirmed the state judgments and held that a jury trial is not constitutionally required in the adjudicative phase of state juvenile delinquency proceedings.
- A plurality opinion reasoned that due process in juvenile court turns on “fundamental fairness,” not a complete transfer of adult criminal-trial rights into juvenile adjudications.
- The plurality concluded a jury is not a necessary element of accurate factfinding such that its absence makes juvenile proceedings unfair.
- The plurality also reasoned that mandating juries could transform juvenile court into a fully adversarial system and diminish its distinctive aims.
- The Court emphasized that states may choose to provide juries (or advisory juries), but the federal Constitution does not compel it.
Legal Principles
- The Fourteenth Amendment requires “fundamental fairness” in juvenile delinquency adjudications, but does not automatically impose every procedural feature of adult criminal trials.
- The Sixth Amendment jury-trial guarantee, even as incorporated against the states, does not extend as a constitutional requirement to juvenile delinquency adjudications.
- The Constitution permits states to preserve procedural differences between juvenile adjudications and adult criminal prosecutions, so long as core due process protections are maintained.
- States remain free to adopt jury trials in juvenile proceedings by statute, rule, or state constitutional law, even though federal law does not mandate them.
Conclusion
McKeiver held that juveniles have no federal constitutional right to a jury trial in delinquency adjudications, limiting the extension of adult criminal procedure into juvenile court while retaining due process protections measured by fundamental fairness.