## Facts

- A Maine juvenile court adjudicated Michael Edward Shone a juvenile offender and, on May 15, 1967, committed him to the Boys Training Center for the term of his minority unless sooner discharged.
- Shortly after commitment, Training Center officials deemed Shone incorrigible and, at age 15, transferred him administratively to the Men’s Correctional Center around May 28, 1967.
- Maine’s transfer statute allowed such a transfer upon the Training Center superintendent’s certification and the Commissioner’s approval, without a judicial hearing, for certain disruptive or noncompliant children (and only if age 15 or older).
- The Boys Training Center was treated as a juvenile, rehabilitative institution; the Men’s Correctional Center was treated as a more restrictive correctional/reformatory facility.
- After exhausting state remedies, Shone sought federal habeas relief, claiming the transfer and resulting confinement violated the Fourteenth Amendment’s Due Process and Equal Protection Clauses.
- The federal district court denied relief, and Shone appealed.

## Issues

1. Whether transferring a juvenile offender from a juvenile training institution to a functionally different correctional institution without a judicial hearing violates the Equal Protection Clause when other youths may be committed to that correctional institution only after a judicial hearing.
2. Whether the transfer and confinement without an additional hearing violates due process where the juvenile has already been adjudicated and committed for the term of minority.

## Decision

- The First Circuit affirmed the district court’s dismissal of the habeas petition.
- The court held that the administrative transfer under the Maine statute, without a new judicial hearing, did not violate equal protection or due process in these circumstances.
- The court treated the transfer as an administrative reclassification within the scope of the existing juvenile commitment, not a new commitment or extension of confinement.

## Legal Principles

- Equal protection prohibits denying procedural protections to persons similarly situated based solely on an arbitrary status classification, but the claimant must be similarly situated to the comparison group.
- A state may treat juveniles already adjudicated and committed differently from youths not yet subject to any custody order, so long as the distinction is rationally related to the different status of the groups.
- An administrative transfer that does not increase the legally authorized term of confinement, and that operates within the terms of an existing judicial commitment, may be handled through correctional classification rather than a new judicial proceeding.
- Due process does not necessarily require an additional judicial hearing for a change in institution where the original adjudication supplied the judicial basis for custody and the transfer does not lengthen the commitment.

## Conclusion

The court upheld Maine’s procedure permitting administrative transfer of an adjudicated juvenile offender from a juvenile training center to a more restrictive correctional facility without a separate judicial hearing, reasoning that the original commitment authorized continuing administrative placement decisions and that the different procedures for initially uncommitted youths were rationally related to their different legal status.


Shone v. State of Me., 406 F.2d 844 (1st Cir. 1969)