## Facts

- Wayne Woodard and Eddie Bell were each 16 years old when indicted by Florida grand juries for robbery-related offenses.
- Florida law (Fla. Stat. § 39.02(5)(c), as then in force) automatically removed juvenile-court jurisdiction when a juvenile was indicted for an offense punishable by death or life imprisonment, placing the case in adult criminal court without a separate transfer hearing.
- Woodard was indicted as an adult for offenses including robbery (life-punishable), pleaded guilty, and was sentenced to five years in the state corrections system.
- Bell was indicted for robbery, pleaded guilty to assault with intent to commit robbery, and received a sentence of six months to fifteen years.
- Each petitioner challenged the constitutionality of the automatic-transfer statute in state proceedings without success and then sought federal habeas relief under 28 U.S.C. § 2254.
- Two federal district courts denied relief; the Fifth Circuit consolidated the appeals.

## Issues

1. Whether Fla. Stat. § 39.02(5)(c), which automatically divests juvenile-court jurisdiction upon grand jury indictment for life- or death-punishable offenses, violates the Due Process Clause by requiring no individualized transfer hearing.
2. Whether the statute violates the Equal Protection Clause by treating indicted juveniles charged with the most serious offenses differently from other juveniles processed in juvenile court or transferred under other procedures.
3. Whether Bell adequately exhausted state remedies for federal habeas purposes despite not seeking review in the Florida Supreme Court.

## Decision

- The Fifth Circuit affirmed the denials of habeas corpus relief to Woodard and Bell.
- The court upheld the constitutionality of Fla. Stat. § 39.02(5)(c) against due process and equal protection challenges.
- The court accepted that Bell’s state remedies were adequately exhausted and decided his constitutional claims on the merits.

## Legal Principles

- There is no federal constitutional right to juvenile-court treatment; a state is not constitutionally required to provide a juvenile court system or to try juveniles in juvenile court.
- Due process does not, by itself, require a state to provide a separate, individualized juvenile transfer (waiver) hearing before prosecuting a juvenile as an adult when state law assigns adult jurisdiction based on a grand jury indictment for specified serious offenses.
- *Kent*’s hearing requirements were treated as tied to the statutory framework at issue there and not as a universal constitutional mandate applicable to all state transfer schemes.
- Equal protection challenges to offense-severity-based juvenile transfer classifications are reviewed under rational-basis scrutiny when no suspect class or fundamental right is implicated.
- A state may rationally classify juveniles indicted for offenses punishable by death or life imprisonment for automatic adult prosecution to further legitimate interests such as public safety and differentiated treatment of serious crime.

## Conclusion

The Fifth Circuit held that Florida could constitutionally require adult prosecution of juveniles indicted for life- or death-punishable offenses through an automatic jurisdictional rule triggered by grand jury indictment, and it affirmed the denial of federal habeas relief to both petitioners.


Woodard v. Wainwright, 556 F.2d 781 (5th Cir. 1977)