Summary of McKeiver v. Pennsylvania
Citation: 403 U.S. 528 (1971)
Relevant Facts: Joseph McKeiver was charged with robbery, larceny, and receiving stolen goods. All three offenses were felonies under Pennsylvania law. However, McKeiver was only sixteen at the time of his arrest. Represented by counsel at the time of his adjudication hearing, McKeiver requested a jury trial. His motion was denied. Tried by a Pennsylvania Judge in the Family Division, McKeiver was adjudged as a delinquent based on his guilt in the crimes charged. He was sentenced to probation and his sentence was affirmed, without opinion, on appeal. Consolidated with another Pennsylvania case and a group of North Carolina cases, McKeiver appealed on this issue of his right to a jury trial for juvenile proceedings.
Issue: Whether a jury trial is constitutionally required in a juvenile delinquency proceeding in state court?
Holding: No, juvenile defendants are not entitled to a jury trial for the adjudicative phase of state delinquency proceedings.
Reasoning: Justice Blackmun announced the judgment of the Court. While a fractured Court failed to reach a consensus regarding their reasoning, the Court held that jury trials are not required for the adjudicative proceedings in the juvenile justice systems of the States.
Concurrence : Justice Blackmun delivered an opinion, joined by Chief Justice Burger and Justices Stewart and White. Justice Blackmun and the plurality explained that the relevant standard for juvenile proceedings is fundamental fairness. While juvenile delinquency proceedings are substantially similar to adult criminal trials, and often result from the same acts or offenses, accurate fact finding under the circumstances does not compel the participation of the jury. Furthermore, the plurality pointed out that juvenile offenders have never been afforded all the protections of adult criminal defendants. While Justice Blackmun recognized the shortcomings of juvenile justice systems in many states, he also pointed out that adding a right to a jury trial would neither remedy the problems complained of nor provide substantial assistance to the courts in their fact-finding role. In the absence of a constitutional guarantee, states should be free to experiment with various systems. Finally, adding a required jury component to every juvenile proceeding would make the process more fully adversarial and ignore the unique concerns of the juvenile justice system while also entailing substantial costs through delays and additional formalities.
Justice White concurred, writing separately to emphasize the substantive differences between criminal and juvenile courts. He concluded, consistent with precedent that juvenile proceedings are not trials within the meaning of the Sixth Amendment and that adding procedural safeguards necessary in criminal trials to juvenile proceedings would be unnecessary in light of the important differences between the two.
Justice Brennan concurred in part and dissented in part. While Justice Brennan agreed that jury trials were not constitutionally required, he argued that other safeguards should be provided to provide the same protections the Sixth Amendment is designed to afford. Specifically, he found the role of the public in juvenile trials of significant importance. Accordingly, he concurred with regard to the Pennsylvania cases, absent evidence that the public was excluded, but dissented with regard to the North Carolina Cases.
Justice Harlan concurred in the judgments. He argued that the Sixth Amendment does not compel jury trials in juvenile proceedings unless and until those proceedings become the substantial equivalent of criminal prosecutions, a development he hinted many states were moving towards.
Dissent: Justice Douglas dissented, joined by Justices Black and Marshall. The dissenters argued that the key analysis under the Sixth Amendment was neither the classification of the proceedings as criminal or juvenile nor the punishment imposed. Rather, the dissenters suggested that juveniles “tried" on charges that would afford adults a jury trial should also be provided with the right to demand a jury trial. Citing the nature of the offenses here and the potential for substantial punishment (and societal judgment) the dissenters saw no reason why the Sixth Amendment, as applied to the states through the Fourteenth Amendment, should not apply to juvenile offenders charged with committing crimes that would be punishable at law if committed by adults.
Conclusion: The Sixth Amendment does not require jury trials for juvenile court proceedings, and the Court continued in its refusal to classify juvenile proceedings as trials under the terms of the Sixth Amendment. This case produced a fractured Court and no majority opinion, with the plurality suggesting substantial room for state variation so long as fundamental fairness was guaranteed.