## Facts

- The State filed a juvenile-delinquency petition charging D.J. and another juvenile with attempted second-degree murder and carrying a firearm on school property.
- Because the allegations involved extremely serious conduct, D.J. sought a jury trial in juvenile court.
- The juvenile court granted the request and concluded that the Louisiana provision barring jury trials in serious delinquency adjudications was unconstitutional.
- The State sought review in the Louisiana Supreme Court, arguing that juvenile delinquency adjudications are tried to the judge, not a jury, and that the juvenile court lacked authority to order a jury trial based on its constitutional ruling.
- The case presented a direct conflict between (1) D.J.’s claim that the gravity of the charges required a jury trial and (2) Louisiana’s statutory framework treating delinquency proceedings as nonjury adjudications in juvenile court.

## Issues

1. Whether a juvenile charged in a delinquency proceeding with attempted second-degree murder and a firearm offense has a constitutional right to a jury trial, making unconstitutional Louisiana’s statutory bar on jury trials in such proceedings.

## Decision

- The Louisiana Supreme Court held that D.J. was not entitled to a jury trial in the juvenile delinquency proceeding.
- The court upheld the constitutionality of Louisiana’s statutory prohibition on jury trials in serious juvenile delinquency adjudications.
- The court reversed the juvenile court’s order granting a jury trial and remanded for further proceedings consistent with a judge-tried juvenile adjudication.

## Legal Principles

- Juvenile delinquency adjudications are not treated as “criminal prosecutions” in the same manner as adult criminal cases for purposes of the jury-trial guarantee.
- The federal Constitution does not require jury trials in juvenile delinquency proceedings; due process in juvenile court can be satisfied through judge-tried adjudications with other procedural protections.
- States may structure juvenile courts to emphasize rehabilitation and individualized dispositions, and they may treat the fact-finding function differently from adult criminal trials without automatically violating constitutional jury-trial provisions.
- A lower court may not create a jury-trial right in juvenile court by invalidating a legislative choice unless a constitutional provision clearly requires juries in delinquency adjudications.

## Conclusion

State in the Interest of D.J. addressed whether the seriousness of alleged delinquent acts transforms a juvenile adjudication into a proceeding that must be tried to a jury. The Louisiana Supreme Court concluded it does not: juvenile delinquency remains a juvenile-court matter tried to the judge under Louisiana’s statutory design, and neither federal jury-trial doctrine nor state constitutional guarantees required a jury here. Accordingly, the court upheld the statute barring jury trials in delinquency proceedings, reversed the juvenile court’s order granting a jury trial to D.J., and remanded for continued proceedings in juvenile court without a jury.


State in the Interest of D.J., 817 So. 2d 26 (2002)