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Breed v. Jones

Supreme Court of United States
421 U.S. 519 (1975)
ELI5:

Rule of Law:

The Double Jeopardy Clause of the Fifth Amendment, applicable to the states through the Fourteenth Amendment, prohibits prosecuting a juvenile in a court of general criminal jurisdiction after an adjudicatory proceeding in juvenile court where the juvenile was found to have violated a criminal statute. Jeopardy attaches in a juvenile adjudicatory proceeding once the court, as the trier of fact, begins to hear evidence.


Facts:

  • Gary Jones, a 17-year-old, was a resident of Los Angeles County, California.
  • On or about February 8, 1971, Jones was alleged to have committed a robbery.
  • During the alleged commission of the robbery, Jones was armed with a deadly weapon.

Procedural Posture:

  • A petition was filed in the Superior Court of California, Juvenile Court, alleging Jones committed robbery.
  • The Juvenile Court held an adjudicatory hearing, heard testimony, and sustained the petition, finding that Jones had committed the alleged acts.
  • Following a dispositional hearing, the Juvenile Court found Jones unfit for treatment as a juvenile and ordered him to be prosecuted as an adult.
  • Jones's petitions for writs of habeas corpus in the state courts were denied.
  • An information was filed against Jones in the Superior Court of California (adult criminal court).
  • The Superior Court found Jones guilty of first-degree robbery and committed him to the California Youth Authority.
  • Jones then filed a petition for a writ of habeas corpus in the U.S. District Court, alleging a double jeopardy violation.
  • The District Court denied the petition.
  • Jones (appellee) appealed to the U.S. Court of Appeals for the Ninth Circuit, which reversed the District Court's decision, finding a double jeopardy violation had occurred.
  • The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.

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Issue:

Does the prosecution of a juvenile in adult criminal court, following a juvenile court adjudicatory hearing that found the juvenile had violated a criminal statute, violate the Double Jeopardy Clause of the Fifth Amendment?


Opinions:

Majority - Mr. Chief Justice Burger

Yes, the prosecution of a juvenile in adult court after an adjudicatory hearing in juvenile court violates the Double Jeopardy Clause. A juvenile is put in jeopardy at an adjudicatory proceeding whose purpose is to determine whether he has committed acts that violate a criminal law and whose potential consequences include both stigma and a substantial deprivation of liberty. The Court reasoned that there is no persuasive distinction between the risks faced in a juvenile adjudicatory hearing and those in a traditional criminal prosecution. Jeopardy attaches when the Juvenile Court, as the trier of facts, begins to hear evidence. Subjecting Jones to a second trial in adult court for the same offense constituted a classic violation of the Double Jeopardy Clause's protection against multiple trials and the associated personal strain and anxiety. The state's interest in maintaining the flexibility of the juvenile court system is insufficient to justify an exception to this fundamental constitutional protection, meaning the decision to transfer a juvenile to adult court must be made before jeopardy attaches in an adjudicatory hearing.



Analysis:

This decision significantly extended the constitutional protection against double jeopardy to juvenile proceedings, continuing the trend established by cases like In re Gault and In re Winship. By holding that jeopardy attaches at the adjudicatory stage, the Court effectively eliminated the practice of states using juvenile hearings as a 'test run' for adult prosecutions. The ruling forced a nationwide restructuring of juvenile justice procedures, requiring states to make the critical decision of whether to try a minor as an adult before any trial on the merits begins. This established a clear procedural safeguard, preventing juveniles from enduring the ordeal of multiple trials for the same offense.

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