## Facts

- Separate juvenile petitions alleged S.S. and L.B. were juveniles “living in circumstances of manifest danger of falling into habits of vice or immorality” under 15 M.R.S.A. § 2552.
- The juvenile court adjudged each a “juvenile offender” on that basis and committed each to a state institution.
- Each juvenile sought release by filing a post-conviction habeas corpus petition challenging the commitments on federal and state constitutional grounds.
- The habeas cases were consolidated and reported to the Maine Supreme Judicial Court on an agreed statement under M.R. Civ. P. 72(b).
- The record did not describe the juveniles’ specific alleged conduct beyond the statutory language, leaving only a facial constitutional challenge to the statute.

## Issues

1. Whether the statutory phrase “living in circumstances of manifest danger of falling into habits of vice or immorality” is unconstitutionally vague under due process.
2. Whether due process prohibits adjudicating and committing a juvenile based on conduct or circumstances that would not be a criminal offense if committed by an adult.
3. Whether equal protection is violated because juveniles may be committed for noncriminal (as to adults) conduct or circumstances.

## Decision

- The court upheld the statute on its face and answered the reported questions for the State.
- The court held the challenged language was not unconstitutionally vague, emphasizing the limiting effect of “manifest danger” and the juvenile-law context.
- The court rejected the claim that due process bars juvenile court intervention for noncriminal (as to adults) conduct or circumstances.
- The court rejected the equal protection claim, concluding different treatment of juveniles and adults was constitutionally permissible given the protective, rehabilitative purpose of juvenile jurisdiction.
- The juveniles’ habeas corpus relief was denied, leaving the commitments in place.

## Legal Principles

- A vagueness challenge is assessed in light of statutory qualifiers and context; “manifest danger” can meaningfully confine a broadly worded standard in a juvenile protective scheme.
- On a facial challenge, the court asks whether the statutory language is inherently unconstitutional, not whether a particular application is supported by sufficient facts.
- Due process does not require that juvenile jurisdiction be limited to conduct that would be criminal if committed by an adult when the statutory aim is protection and rehabilitation rather than criminal punishment.
- Equal protection permits differential treatment of juveniles and adults when the age-based classification is rationally related to legitimate state interests in safeguarding minors and providing early intervention.

## Conclusion

The Maine Supreme Judicial Court sustained the juvenile statute authorizing commitment when a juvenile is in “manifest danger” of falling into “habits of vice or immorality,” holding the standard was not facially vague and that the Constitution does not require juvenile commitments to be limited to conduct that would be criminal for adults.


S.S. & L.B. v. State, 299 A.2d 560 (Me. 1973)