Golden v. State
21 S.W.3d 801, 341 Ark. 656 (2000)
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Rule of Law:
The Due Process Clause requires that a juvenile be afforded a hearing to determine competency to proceed prior to adjudication. However, neither the Due Process nor the Equal Protection Clause requires that a juvenile be permitted to assert an insanity defense in juvenile proceedings.
Facts:
- Andrew Golden was eleven years old at the time of the incident.
- On March 24, 1998, Golden and another student, Mitchell Johnson, opened fire on their classmates and teachers at Westside Elementary School in Jonesboro, Arkansas.
- The shooting resulted in the deaths of one teacher and four students.
- Additionally, one teacher and nine students were wounded in the attack.
Procedural Posture:
- A petition was filed in juvenile court charging Andrew Golden with five counts of capital murder and ten counts of first-degree battery.
- At a probable cause hearing, Golden's attorney informed the court of his intent to raise the insanity defense and challenge Golden's competency to stand trial.
- The trial court held a hearing and ruled that, due to the nature of juvenile proceedings, Golden was not entitled to a competency determination or to assert the insanity defense.
- Following an adjudication hearing where his attorney stipulated to the facts, the trial court adjudicated Golden guilty.
- Golden appealed the trial court's order directly to the Supreme Court of Arkansas.
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Issue:
Does the Due Process Clause require that a juvenile be afforded a competency hearing prior to adjudication, and do the Due Process and Equal Protection Clauses require that a juvenile be allowed to assert an insanity defense in juvenile proceedings?
Opinions:
Majority - W.H. “Dub” Arnold, Chief Justice
Yes, as to the competency hearing; No, as to the insanity defense. A juvenile has a due process right to have their competency determined prior to an adjudication hearing, but there is no constitutional right to assert an insanity defense in juvenile proceedings. The court reasoned that the right to counsel, guaranteed to juveniles in In re Gault, would be meaningless if the juvenile were incompetent and unable to communicate with their attorney or understand the proceedings. Therefore, a competency hearing is an essential element of due process. Regarding the insanity defense, the court held there is no fundamental constitutional right to it, relying on Medina v. California. For equal protection, the court found a rational basis to distinguish between juveniles and adults because the juvenile system is rehabilitative rather than punitive, and its procedures and potential outcomes are fundamentally different from the adult criminal system.
Dissenting - Lavenski R. Smith, Justice
No, a juvenile does not have a due process right to a competency hearing. The dissent argues that the juvenile justice system is fundamentally different from the adult criminal system, operating under the state's parens patriae interest to protect the child. The juvenile code implicitly presumes a degree of incompetence in children, and the proceedings are designed to function with this in mind. Requiring adult-style competency hearings erodes the essential distinctions between the two systems and is unwise, as the state's interest in a child's welfare, as outlined in cases like Schall v. Martin, can subordinate the child's liberty interests. There is a rational basis for the juvenile code not providing for competency hearings.
Analysis:
This decision clarifies the scope of due process rights for juveniles by extending the principles of In re Gault to include the right to a pre-adjudication competency hearing, recognizing it as essential for fundamental fairness. However, the court simultaneously reinforces the distinction between the adult and juvenile justice systems by holding that not all rights afforded to adults, such as the insanity defense, are required in the rehabilitative-focused juvenile system. This ruling establishes a key precedent in juvenile law, balancing the need for procedural protections with the unique parens patriae philosophy of juvenile courts, and it will guide future cases on which adult criminal procedures must be incorporated into juvenile proceedings.
