## Facts

- The State filed a juvenile-delinquency petition alleging R.L.R., a minor, unlawfully sold LSD to an informant, Joseph Want, on or about December 11, 1968.
- Before adjudication, the court held a testimony-perpetuation hearing for a federal chemist who identified a tablet received from police as LSD; R.L.R. was not present, but counsel attended.
- At the adjudicatory hearing, Want testified he bought a tablet from R.L.R. at a pool hall and delivered it to a police officer who had provided purchase money.
- R.L.R. denied the sale and testified he was in school when it allegedly occurred.
- The children’s court adjudicated R.L.R. delinquent after a nonjury, closed adjudicatory hearing.
- At disposition, a different judge ordered R.L.R. remain in state custody until an indefinite time up to his 21st birthday, with broad placement authority.

## Issues

1. Whether the Alaska Constitution guarantees a juvenile the right to a jury trial in a delinquency proceeding based on acts that would be criminal and punishable by incarceration if committed by an adult.
2. Whether the Alaska Constitution guarantees a juvenile the right to a public trial in such a delinquency adjudication, notwithstanding rules providing for closed hearings.
3. Whether procedural rules governing juvenile proceedings (including notice/service requirements) were properly applied and could limit these constitutional protections.

## Decision

- The Alaska Supreme Court reversed the delinquency adjudication and remanded for further proceedings consistent with its opinion.
- The court held that a juvenile has a state constitutional right to a jury trial when charged with conduct that would be a crime subject to incarceration if committed by an adult.
- The court held that the state constitutional right to a public trial applies to juvenile delinquency adjudications, and blanket closure by rule is impermissible absent narrowly justified exceptions.
- Because the decision rested on the Alaska Constitution, the court did not decide the corresponding federal constitutional questions.
- The court addressed additional procedural objections (including service/notice matters) as secondary to the constitutional violations requiring reversal.

## Legal Principles

- When a child in a delinquency proceeding is charged with acts that would constitute a crime punishable by incarceration if committed by an adult, the Alaska Constitution guarantees the right to a jury trial.
- Constitutional protections turn on the substance of the proceeding and the potential loss of liberty, not the “civil” label attached to delinquency adjudication.
- The Alaska Constitution’s public-trial guarantee extends to juvenile delinquency adjudications; closure cannot be automatic and must be justified by specific, narrowly tailored reasons.
- Court rules and procedural frameworks for juvenile cases cannot curtail state constitutional rights.

## Conclusion

The Alaska Supreme Court required that juveniles facing delinquency adjudications for criminal-type conduct with incarceration-like consequences be afforded a public jury trial under the Alaska Constitution, invalidating nonjury and blanket-closure practices in such cases and reversing R.L.R.’s adjudication for a new, constitutionally compliant proceeding.


R.L.R. v. State, 487 P.2d 27 (Alaska 1971)